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PRIVACY



Privacy Statement

Effective Date: December 14, 2021

This Privacy Statement describes the practices of Alston & Bird LLP (“Alston &
Bird”, “we” or “us”) with respect to personal information we collect through our
Web sites and mobile applications that display or link to this Statement (the
“Sites”). Collection of Personal Information We collect personal information
that you voluntarily provide when you visit our Sites. For example, we collect
information about you when you:

 * Sign up to receive advisories, articles, announcements or other
   communications;
 * Register for an event;
 * Apply for a job with Alston & Bird; or
 * Submit a comment or question or otherwise communicate with us through the
   Sites.

The personal information we collect may include your first and last name, street
address, telephone number, email address, communication preferences, password,
and other information you submit through the Sites. If you apply for a job
through our Sites, we may gather additional information about you, such as your
resume, cover letter, work history, reference information, education
information, information required to complete a background check and any other
information you elect to provide us (e.g., career objectives, willingness to
relocate, awards or professional memberships).

We also collect certain information automatically when you visit our Sites
(“Technical Information”). Technical Information includes the IP address of your
device; the type of browser, device and operating system you use; other
identifiers associated with the device you use to access our Sites; the pages
you visit and the features you use, including dates and times; and if you
navigated from or navigate to another Web site, the address of that Web site. We
may collect Technical Information through the use of cookies, clear .gifs, web
beacons, local shared objects, Flash cookies or other tags, identifiers or
technologies as they may become available or change over time. We may track the
total number of visitors to our Sites, the number of visitors to each page of
our Sites, whether visitors share our Sites with others, and the domain names of
our visitors’ Internet service providers. We may also collect information
regarding the effectiveness of our email or other communications, such as
whether you open an email we send to you. Please note that third party ad
networks and service providers may receive Technical Information and use and
disclose such Technical Information for their own purposes, subject to their own
privacy policies. You can opt out of delivery of targeted advertising to you by
multiple ad networks by visiting http://www.aboutads.info/choices/. We use
AddThis so you can share content from our website across social networks. For
information about AddThis’s privacy practices, please
visit https://www.oracle.com/legal/privacy/addthis-privacy-policy.html. Our
Sites also use Google Analytics to analyze your website activity. You can opt
out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

How We Use Personal Information Collected through the Sites  We use personal
information we collect through our Sites to contact you, to provide you with
information that you have requested, to provide additional information which we
believe may be of interest to you, to perform an activity you have requested
(such as to register you for an event or to evaluate an application for a job
opportunity), to enhance or improve the Sites, for security purposes, or
otherwise to operate our business. Sharing of Personal Information  We may share
personal information with third parties in the following circumstances:

 * When authorized by you.
 * With third party service providers retained to perform services on our
   behalf. These service providers are not authorized to use or disclose the
   information except as necessary to provide services to us.
 * If we are required to do so by law or pursuant to legal process, or in
   response to a request from law enforcement authorities or other government
   officials.
 * When we believe disclosure is necessary or appropriate to prevent physical
   harm or financial fraud or theft, or in connection with an investigation of
   suspected or actual illegal activity.
 * In connection with the sale or transfer of all or a portion of our business
   or assets to a third party.

Your Choices and Rights

You may unsubscribe from advisories, articles, announcements and other
promotional emails received from us by following the unsubscribe link included
at the bottom of each such email or by contacting us at privacy@alston.com.
Please note that you may continue to receive non-promotional communications to
the extent permitted by law. Your browser and your device may enable you to
limit the use of cookies and other technologies used to collect Technical
Information. You should consult documentation for your browser or device for
more information about exercising these options. Please note that you may not be
able to use all the features of our Sites if you limit the Technical Information
you share with us. In addition, our Sites are not designed to respond to "do not
track" requests from browsers. To request details of the personal information we
hold about you or to delete or rectify any inaccurate personal information about
you please contact us at privacy@alston.com. We will handle any such request in
accordance with applicable law. Please note that we may take reasonable steps to
verify your identity before implementing your request.

Information Security 

We maintain administrative, technical and physical safeguards for the Sites
designed to protect against loss, misuse or unauthorized access, disclosure,
alteration or destruction of the personal information we collect through our
Sites. The use of the Internet creates inherent information security risks, and
we are not able to guarantee the security of our Sites.

Transfers of Personal Information

We may transfer the personal information we collect through the Sites to
countries with laws that may be deemed not to provide the same level of data
protection as the laws in the country in which you reside. Please note that our
primary data processing facilities are located in the United States of America.
By submitting personal information through the Sites, you consent to the
transfer of personal information as described in this Privacy Statement.

Linked Sites 

The Sites may include links to sites operated by external third parties. The
inclusion of a link to a third party site does not imply our endorsement of the
site or the products and services offered at such site. Please note that this
Privacy Statement does not apply to any such third-party sites. You should
consult the privacy policies of each site you visit.

Additional Notice for California Consumers

This part of our Privacy Statement applies to consumers who reside in the State
of California.

We describe the personal information we have collected from consumers in the
twelve (12) months preceding the effective date of this Privacy Statement in the
part of our Privacy Statement titled “Collection of Personal Information.”  The
information we have obtained includes the following:

 * Identifiers such as a real name, postal address, telephone number, Internet
   Protocol address, email address, social security number, driver’s license
   number, or other similar identifiers.
 * Personal information described in subdivision (e) of Section 1798.80
   (California Customer Records statute). This means any information that
   identifies, relates to, describes, or is capable of being associated with, a
   particular individual, including, but not limited to, identifiers listed
   above.
 * Internet or other electronic network activity information, including, but not
   limited to, browsing history, search history, and information regarding a
   consumer’s interaction with an Internet Web site, application, or
   advertisement.
 * Electronic, visual or similar information.
 * Professional or employment-related information.
 * Education information, defined as information that is not publicly available
   personally identifiable information as defined in the Family Educational
   Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
 * Inferences drawn from any of the information identified in this subdivision
   to create a profile about a consumer reflecting the consumer’s preferences,
   characteristics, psychological trends, predispositions, behavior, attitudes,
   intelligence, abilities, and aptitudes (e.g., we may collect this information
   in connection with website analytics or job applications).

We collect this personal information when you use our Sites.  For more
information, please see “Collection of Personal Information” above. We have not
disclosed to other businesses or third parties any personal information for
monetary or other valuable consideration within the twelve (12) months preceding
the effective date of this Statement. 

We have disclosed personal information to our service providers for business
purposes in the prior twelve (12) months. The information we have disclosed for
business purposes may include some or all of the categories listed above. For
more information about the categories of entities to which we have disclosed
this information and the purposes for which we have disclosed the information,
please see “Sharing of Personal Information” above.

Your California Privacy Rights 

If you are a California resident, you have certain rights in the information
listed in this Additional Notice for California Consumers. You may exercise
these rights free of charge except as otherwise permitted under applicable law.
These rights are as follows:

 * Right to Deletion of Personal Information. You have the right to request that
   we delete personal information about you which we have collected from you.
 * Right to Access and Information regarding Personal Information. You may
   request that we disclose to you: the categories of California Personal
   Information we have collected about you;
   * the categories of sources from which the California Personal Information is
     collected;
   * our business or commercial purpose for collecting or selling California
     Personal Information;
   * the categories of third parties with whom we share California Personal
     Information;
   * the specific pieces of information we have collected about you;
   * the categories of personal information about you, if any, that we have
     disclosed for monetary or other valuable consideration and the categories
     of third parties to which we have disclosed the information, by category or
     categories of personal information for each third party to which we
     disclosed the personal information; and
   * the categories of personal information about you that we disclosed for a
     business purpose.
 * Right to Opt Out. You have the right to opt out of the disclosure of personal
   information about you for monetary or other valuable consideration.

You may request to exercise these rights by:
 * Submitting a request
   through https://www.alston.com/en/resources/california-rights-request-submission-form;
   or
 * Calling us toll-free at 866-852-0559.

As required or permitted under applicable law, please note that we may take
steps to verify your identity before granting you access to information or
acting on your request to exercise your rights. We may limit our response to
your exercise of the above rights as permitted under applicable law. We may not
discriminate against you in response to your exercise of the above rights,
including by:
 * Denying goods or services to you;
 * Charging different prices or rates for goods or services, including through
   the use of discounts or other benefits or imposing penalties;
 * Providing a different level of quality of goods or services to you; or
 * Suggesting that you will receive a different price or rate for goods or
   services or a different level of quality goods or services.

Do Not Track

Please note that our Web sites and mobile apps are not designed to respond to
"do not track" requests from Web browsers.

Changes and Questions 

Alston & Bird may revise this Privacy Statement from time-to-time. Please check
this page periodically for changes. If you have questions about this Privacy
Statement or our practices with respect to personal information, please send
your request to privacy@alston.com.

EU and UK General Data Protection Regulation (GDPR)

Scope

This Privacy Notice (“Notice”) describes how Alston & Bird collects and uses
your Personal Data pursuant to the EU General Data Protection Regulation and the
United Kingdom General Data Protection Regulation (hereafter, unless otherwise
stated, referred to together as “GDPR”) and other applicable data protection and
privacy legislation. It tells you what Personal Data we collect, why we need it,
how we use it and what safeguards are in place to keep it secure.

Key Terms

“Alston & Bird” “we” “us” and “our” refers to Alston & Bird (City) LLP and its
affiliate in the US, Alston & Bird LLP, to the extent that its affiliate is
subject to the GDPR.

“Alston & Bird Personnel” means Alston & Bird’s prospective, present and past
partners, employees, consultants and agency staff, and people connected to such
persons.

“Personal Data” means information about individuals (including you), and from
which such individuals could be identified.

“You” means individuals whose Personal Data we process, including but not
limited to, Alston & Bird’s clients, Alston & Bird’s client personnel,
counter-parties, counter-party personnel, other solicitors / advisors,
witnesses, suppliers, supplier personnel, job applicants and individuals to whom
we send marketing communications. “You” does not include Alston & Bird
Personnel.

Data Controller

Alston & Bird is the Data Controller in relation to your Personal Data and is
committed to protecting the privacy rights of individuals, including your
rights.

Data Protection Manager

Alston & Bird is not required under the GDPR to appoint a Data Protection
Officer and, following a detailed analysis, does not consider it appropriate to
do so on a voluntary basis.

Alston & Bird has however, appointed a Data Protection Manager (“DPM”), who is
responsible for overseeing Alston & Bird’s compliance with the GDPR and any
other applicable data protection legislation and regulation. The DPM can be
contacted at privacy@alston.com.

In addition, our Compliance Officer for Legal Practice (“COLP”) oversees
compliance with our professional responsibilities and with legislative
requirements.

How does Alston & Bird obtain your Personal Data?

In some circumstances, we may obtain your Personal Data from you directly
including through your use of this website or a job application but, more
typically, we will obtain your Personal Data from a third-party source, for
example, we may collect information from our clients / our clients’ personnel,
agents and advisors, other law firms / advisors which represent you, the company
for whom you work, other organisations / persons with whom you have dealings,
government agencies, credit reporting agencies, recruitment agencies,
information or service providers and publicly available records.

What about Personal Data which you provide to Alston & Bird?

If you provide information to us about someone else (such as one of your
associates, directors or employees, or someone with whom you have business
dealings) you must ensure that you are entitled to disclose that information to
us and that, without our taking any further steps, we may process that
information in accordance with this Notice.

What Personal Data does Alston & Bird collect from and about you?

We collect and use different types of Personal Data about you, which will vary
in type and detail depending on the circumstances and purpose of processing.
Please consider the following illustrative and non-exhaustive examples:

 * Personal Data about you: name, address, date of birth, marital status,
   nationality, race, gender, preferred language, job title, work life and
   restrictions and / or required accommodations, possibly about your family
   life;
 * Personal Data to contact you at work or home: name, address, telephone, and
   e-mail addresses;
 * Personal Data which may identify you: photographs and video, passport and /
   or driving license details, electronic signatures;
 * Personal Data to process any payment we might need to make to or receive from
   you: bank account details, HMRC numbers and references (where applicable);
   and
 * Personal Data to monitor your use of our website: IP address, traffic and
   location information, weblogs and other communication information.

Why do we need to collect and use your Personal Data?

We need to collect and use your Personal Data for a number of reasons, the
primary purpose being to provide legal advice and services to our clients and
which may involve the use of your Personal Data in the following
(non-exhaustive) ways:

 * to contact you if you are involved in a matter we are undertaking for a
   client, whether in your professional or personal capacity;
 * to carry out investigations, risk assessments and client due diligence;
 * to analyse the practices of your employer or other organisations and / or
   persons with whom you have dealings;
 * to review, draft and disclose correspondence and other documents, including
   court documents;
 * to instruct third-parties on behalf of our clients; and
 * for comparison / analytical purposes and to formulate legal opinions and
   provide advice.

We may also process your Personal Data for effective business management
purposes which may involve the use of your Personal Data in the following
(non-exhaustive) ways:

 * to engage and contact suppliers;
 * to carry out internal reviews, investigations, audits;
 * to conduct business reporting and analytics;
 * to advertise and market the services that we provide;
 * to help measure performance and improve our services;
 * for recruitment purposes;
 * for regulatory and legislative compliance and related reporting; and
 * for the prevention and detection of crime.

What is Alston & Bird’s legal basis for processing your Personal Data?

Under the GDPR, Alston & Bird must identify a lawful basis for processing your
Personal Data which may vary according to the type of Personal Data processed
and the individual to whom it relates.

– Performance of a contract with you (where applicable):

Alston & Bird is entitled to process the Personal Data it requires in order to
fulfil its obligations under its contract with you. This will be the relevant
legal basis if you are an individual client or supplier / other individual with
a direct contractual relationship with Alston & Bird.

– Legitimate interests of Alston & Bird or a third-party:

We process some of your Personal Data on the basis that it is in our legitimate
interests and / or the legitimate interests of a third-party to do so. This will
primarily concern the processing of Personal Data that is necessary to provide
legal advice and services to our clients. Alston & Bird’s legitimate business
interest in such instances is the proper performance of its function as an
authorised and regulated provider of legal services. Alston & Bird’s clients
also have a legitimate interest (and more general right in law) in obtaining
legal advice and services.

Alston & Bird’s broad interest in the provision of legal services as a basis for
processing your Personal Data, and our clients’ corollary interest in the
receipt of such services, can be broken down into more discreet categories which
may include, but are not limited, to:

 * the interest in contacting individuals relevant to Alston & Bird’s work and
   our clients’ matters, which may involve the use of your Personal Data;
 * the interest in reviewing documents and correspondence that have been
   disclosed to Alston & Bird, Alston & Bird’s clients and third-parties, which
   may contain your Personal Data;
 * the interest in reviewing and analysing all evidence available to Alston &
   Bird and its clients, which may contain your Personal Data;
 * the interest in adducing legal arguments, creating documents and
   correspondence, which may contain your Personal Data;
 * the interest in disclosing documents and correspondence, which may contain
   your Personal Data, to various parties in the furtherance of Alston & Bird’s
   clients’ objectives;
 * the interest in instructing third-parties on behalf of Alston & Bird’s
   clients;
 * the interest in receiving payment from Alston & Bird’s clients and
   third-parties and to facilitate payments to and from Alston & Bird’s clients
   and third-parties; and
 * in order to allow for all of the above, the secure management and storage of
   your Personal Data, within our IT environment and hard-copy filing systems.

Alston & Bird may also process your Personal Data on the basis that it is
necessary for its legitimate business interests in the effective management and
running of Alston & Bird which may include, but is not limited to: engaging
suppliers and supplier personnel; ensuring that its systems and premises are
secure and running efficiently; for regulatory and legislative compliance, and
related auditing and reporting; for insurance purposes; for recruitment / hiring
purposes; for marketing purposes; and to facilitate, make and receive payments.

– Compliance with a legal obligation to which Alston & Bird is subject:

In certain circumstances, Alston & Bird must process your Personal Data in order
to comply with its legal obligations. This might include, but is not limited to,
Personal Data required: for tax and accounting purposes; for conflict checking
purposes as required by the common law and Alston & Bird’s regulators; and for
Alston & Bird to fulfil its compliance and other obligations under relevant
legislation / regulation.

Special category and criminal records Personal Data

If Alston & Bird processes your criminal records Personal Data or special
category Personal Data relating to your racial or ethnic origin, political
opinions, religious and philosophical beliefs, trade union membership, health
data, biometric data or sexual orientation, we will obtain your explicit consent
to those activities unless this is not required by law (because, for example, it
is processed for the purpose of exercising or defending legal claims, or we are
permitted to process the data as attorney-at-law) or the information is required
to protect your health in an emergency. Where we are processing Personal Data
based on your consent, you have the right to withdraw that consent at any time.

Direct Marketing

We may use your contact details to send you marketing materials, provided we are
permitted to do so by law. You always have the right to unsubscribe from any
marketing. You can do so by clicking on the relevant link in the next email we
send you, or by contacting the DPM using the details provided.

Who receives your Personal Data?

We may disclose your Personal Data to third-parties if, but only when, we have a
legal basis to do so. Such recipients include but are not limited to:
co-counsel, other solicitors / barristers / experts / foreign law firms whom we
instruct on your behalf; Alston & Bird’s insurance brokers and underwriters;
Alston & Bird’s bank, auditors and accountants; Alston & Bird’s outsourced IT
providers and other suppliers; HMRC or the Belgian Tax authority; the UK SRA;
Belgian bar associations; the UK Law Society; the other side / other parties on
any given matter (lay and solicitor).

How do we protect your Personal Data?

We have security arrangements in place that are designed to guard against
unauthorised access, improper use, alteration, destruction or accidental loss of
your Personal Data. We take appropriate organisational and technical security
measures and have rules and procedures in place that are designed to ensure that
any Personal Data we hold is not accessed by anyone unauthorised to access it.
We have in place, and abide by, a specific information security policy about the
security standards used to protect your Personal Data.

When we use third-party organisations to process your Personal Data on our
behalf, they must also have appropriate security arrangements, and must comply
with our instructions and contractual requirements concerning the processing of
Personal Data and instructions and must ensure compliance with the GDPR and any
other relevant data protection legislation.

Is your Personal Data transferred to “third countries” and, if so, what
safeguards are in place?

We may transfer your Personal Data to organisations located in countries other
than the one in which the Personal Data was collected. In particular, we may
transfer your Personal Data to the UK, to the U.S., or to Belgium or another
country in the EEA.

In addition to the security arrangements mentioned above in relation to our
engagement of third-party organisations, we will ensure that your Personal Data
is adequately protected, for example, by using a contract for the transfer which
contains specific data protection provisions.

The transfer of your Personal Data from Alston & Bird (City) LLP to Alston &
Bird LLP will constitute a transfer to a “third country” and, accordingly, the
relevant entities have contracted on such a basis. If you wish to see a copy of
this contract, please contact the DPM.

How long will your Personal Data be retained by Alston & Bird?

It is our policy to retain your Personal Data for the length of time required
for the specific purposes for which it is processed by Alston & Bird and which
are set out in this Notice. However, we may be obliged to keep your Personal
Data for a longer period, for example, where required by our legal and
regulatory obligations or in order to ensure we have effective back-up systems.
In such cases, we will ensure that your Personal Data will continue to be
treated in accordance with this Notice, restrict access to any archived Personal
Data and ensure that all Personal Data is held securely and kept confidential.

What are your rights?

The GDPR generally affords individuals a right to access their Personal Data, to
object to the processing of their Personal Data, to rectify, to erase, to
restrict and to port their Personal Data.

We have specific procedures in place in relation to Subject Access Requests
(“SARs”) that you may be entitled to make. Put simply, a SAR is a request made
by you which requires us to provide you with details of your Personal Data which
we hold and process and a description of how we process it. Any questions or
requests should be put in writing to the DPM.

There are exceptions to the rights of individuals in relation to their Personal
Data and, particularly when we are processing your Personal Data for the purpose
of providing legal advice to our clients, your rights may be limited. We will,
at all times, respect your Personal Data and seek to be as transparent as
possible but please be aware that, in some instances, we may be restricted from
even acknowledging that we process your Personal Data.

How to make a complaint

If you are unhappy with the information provided in this Notice or have concerns
about the way in which Alston & Bird processes your Personal Data you may in the
first instance contact the DPM, and if you remain dissatisfied then you may
complain directly to the relevant supervisory authority in the country of your
habitual residence, your place of work, or of an alleged infringement of the
GDPR.

 * The UK Information Commissioner can be contacted at: Information
   Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
   5AF
   * ico.org.uk
 * The Belgian Data Protection Authority’s contact details can be found on the
   following website: https://www.dataprotectionauthority.be/citizen.

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