Last Updated Date: April 1, 2023
This Privacy Notice describes how Troutman Pepper Hamilton Sanders LLP and its wholly owned subsidiaries (collectively, “Troutman Pepper”) collect, use, share, or otherwise process information that relates to you (“Personal Information”).
This Privacy Notice applies to Personal Information that Troutman Pepper collects both online and offline, including in connection with the services we provide, our main website (www.troutman.com), and other websites, mobile applications, and digital communications (such as emails) (collectively, our “Services”).
This Privacy Notice does not apply to information about individuals that Troutman Pepper maintains in the context of our legal representation of clients, which is separately governed by our client agreements and professional responsibilities.
If you have any questions about this Privacy Notice, please email us at firstname.lastname@example.org.
Table of Contents
- Personal Information We May Collect
- How We Use Personal Information
- How We Disclose Personal Information
- Retention of Personal Information
- Your Privacy Rights and Other Choices
- Security Practices
- International Data Transfers
- Links to Other Websites and Services
- Changes to this Privacy Notice
- Governing Law
- How to Contact Us
- Information for California Residents
1. Personal Information We May Collect
The types of Personal Information that we collect about you depend on how you interact with us. This section describes the types of Personal Information we may have collected in the previous 12 months and its sources. Troutman Pepper does not collect any “sensitive personal information,” as that term may be defined by applicable law.
a) Information You Voluntarily Provide to Us. We collect Personal Information that you voluntarily provide to us. This includes, for example, Personal Information you provide when you contact us (including when contacting us on behalf of an organization with which you are affiliated); when you request alerts, event invitations, newsletters, or other informative materials; or when you register for a webinar or event, fill out a form, respond to a survey, or otherwise communicate with us.
The categories of Personal Information that we may collect directly from you include:
Identifiers, such as your name, physical address, email address, telephone number, bar number, signature, government-issued identification number, and account credentials (e.g., username) if you access or use a Troutman Pepper online service, or other similar identifiers.
Professional and Educational Information, such as your current or previous employers, your job title, or other information about the organization with which you are affiliated. You might also provide information about your professional qualifications or your education, such as your bar number, degrees, fields of study, institutions attended, professional memberships, qualifications, and certifications.
Health Information, such as accessibility requirements and dietary restrictions.
User Content, such as comments or other material that you post to our social media pages, blogs, or other forums.
Preferences, such as your stated interests, how frequently you wish to receive our publications or communications.
b) Information We May Generate or Collect Automatically. We may generate or collect automatically certain types of Personal Information when you interact with us and our Services. The type of Personal Information we collect in this context may include:
Identifiers, such as information that uniquely identifies you, such as your name, email address, and username.
Device Information, such as information pertaining to the device through which you interact with our Services, such as your IP address, type of device, operating system and version, MAC address, user settings, or browser type.
Commercial information, such as records of services you obtained from us, including on behalf of an organization with which you are affiliated.
Internet or Other Electronic Network Activity Information, such as your browsing history, search history, and information regarding your interactions with us and our Services, which may include pages that you visited while using our Services, the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
Geolocation Information, such as the region or general location where your computer or device is accessing the internet.
Audio and Visual Information, such as your voice and likeness as captured in photographs, video, or audio recordings, if you attend our events, visit our offices, or leave us a voicemail message.
Inferences drawn from other Personal Information we collect about you that may relate to your preferences, areas of interest, or other matters.
Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
Web Beacons, Clear GIF, Pixels Tag, and Script. These Collection Technologies are small transparent image files or lines of code to record how you interact with our Services. For example, the use of these technologies may allow us to record that a user has visited a particular web page or clicked on a particular feature. We may also include these types of Collection Technologies in emails to understand whether messages have been opened, acted on, or forwarded.
Our use of Collection Technologies generally falls into the categories listed below. Please note that these are the main ways of classifying cookies, although there may be other cookies that will not fit neatly into these categories or may qualify for multiple categories.
|Strictly Necessary||Cookies that are necessary for our websites to function and cannot be switched off in our systems. They are usually only set in response to your actions or request for services, such as setting your privacy preferences, logging in, or filling in forms.|
|Functional||Cookies that enable our website to provide enhanced functionality and personalization based on your interaction with the website (for example, to store your site preferences and choices, such as username, region, and language).|
|Analytics and Performance||Cookies that gather data on how visitors use a website or other digital properties (for example, page visit counts, idle time by a user on a page, bounce rates, and load speeds).|
For information on how to manage your cookies preferences, please see Section 5(c) (Managing Cookie and Other Collection Technologies Preferences) below.
c) Information We Collect from Other Sources. We may obtain Personal Information from other sources, such as our clients, employees, and business partners, or from business contact databases and enrichment services. We may also receive information about you from social media platforms, such as when you interact with us on those platforms or access our social media content. We may collect information about you from publicly available sources, such as public social media profiles, publications, and other websites or materials available through search engine We may collect the following categories of Personal Information from these other sources:
Identifiers, such as name, telephone number, postal or email address, and social media identifiers.
Professional and Educational Information, such as your occupation, employers, business contact information, education (such as your degrees, fields of study, and institutions attended), languages, and professional memberships, qualifications, licenses, and certifications.
User Content that you make available online, such as your social media posts or publications.
2. How We Use Personal Information
We use Personal Information for a variety of purposes, including:
to provide you with access to the Services, including to operate, troubleshoot, and improve our websites, mobile applications, and other digital properties.
to respond to or notify you, including when you contact us with a comment, request, or question; register for an event or webinar; request legal services; or otherwise to send you technical notices, updates, security alerts, and other administrative messages.
to contact you and expand/maintain our list of contacts, including to send you announcements, invitations, publications, and other information or materials that may interest you.
to personalize your experiences with us, including to remember your interests and preferences, and facilitate interactions and introductions.
for research and analytical purposes, including to understand how you access and use our Services and to make improvements to our Services.
for marketing purposes, including to communicate and evaluate our events, publications, and other offerings.
for our business purposes, including to operate and improve our business and Services, internal administration, and data analysis; and for any other business purpose permitted by law.
for legal compliance and safety purposes, including to maintain the security of our clients, employees, and property; respond to court orders, lawsuits, subpoenas, and government requests; support legal and regulatory compliance; detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement; and notify you of any other legal or safety issues.
for purposes that you have otherwise consented to, including at the time your Personal Information is collected.
3) How We Disclose Personal Information
We may disclose the Personal Information we collect only as outlined below.
Service Providers. We may disclose your Personal Information with third parties that provide services on our behalf or help us operate the Services (such as customer support, hosting, data analytics, payment processing, email delivery, marketing, ad measurement services, and database management services). These third-party service providers may use your Personal Information only as directed or authorized by us and are prohibited from using or disclosing your information for any other purpose.
Professional Advisors. We may disclose your Personal Information to professional advisors, such as lawyers, auditors, and insurers, when necessary.
Legal Compliance and Safety. We may disclose your Personal Information for the compliance, fraud prevention, safety, and legal proceedings described above in Section 2 (How We Use Personal Information).
Business Transfers. We may disclose your Personal Information in connection with a business transaction (or potential business transaction), such as a merger, consolidation, acquisition, or in connection with a reorganization, bankruptcy, or dissolution.
Your Consent or Instruction. We may disclose your Personal Information when we have your consent or instruction to do so, for example, providing your name and contact information to a co-sponsor of an event that you attend or a co-author of a publication you request.
We may disclose anonymous, de-identified, or aggregate information that cannot reasonably identify you with others for any purpose, as permitted by applicable law. Please note that any Personal Information that you post to a profile, blog, comment section, or forum on our Services or social media pages may be available to other users of those forums or, in some cases, made publicly available.
4) Retention of Personal Information
We retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another business purpose.
5) Your Privacy Rights and Other Choices
Below are rights and choices you may have with respect to your Personal Information. Please note that some of the rights may vary depending on your state of residence.
a) Privacy Rights. Certain states provide individuals with data rights. Depending on your state of residence, you may have the right to:
Access Your Personal Information, which includes the right to: (1) confirm whether we are processing your Personal Information; (2) confirm the categories of your Personal Information that we process; and (3) obtain a copy of your Personal Information in a portable format.
Correct Your Personal Information. In some cases, we may provide self-service tools that enable you to do so.
Delete Your Personal Information.
Opt Out of Your Personal Information Being Used for Certain Purposes, such as: (1) targeted advertising; (2) the “sale” of your Personal Information; and (3) certain profiling activities that result in legal or similarly significant effects on you. Please note, however, that we do not use Personal Information for any of these purposes.
To exercise the Privacy Rights identified above, please contact us at email@example.com or 800.255.8752, and please reference this Privacy Notice.
If you have questions about your privacy rights or would like to appeal a decision made concerning a privacy request you submitted, please contact us at firstname.lastname@example.org or 800.255.8752.
b) Managing Communication Preferences. If you no longer wish to receive marketing communications from us, you can let us know by contacting us using the information available in Section 12 (How to Contact Us). Our digital marketing communications may provide unsubscribe or opt out mechanisms. Please note that if you opt out of marketing communications, we may still contact you with non-promotional communications, such as those about ongoing business relations or administrative messages.
c) Managing Cookie and Other Collection Technologies Preferences. When you first visit our website, you will be presented with a banner which offers you a choice about whether to accept or reject cookies or Collection Technologies of different types, except for those cookies and Collection Technologies that are necessary for the operation of our sites. You may choose to “Accept” or “Decline” our use of such cookies and Collection Technologies. To revisit your choice, you must first clear the cache and cookies in your web browser. Some browsers allow you to clear the cache and cookies by using the keyboard shortcut, Ctrl + Shift + Delete. Once cleared, you will be presented with the banner on your next visit to our website through which you can update your preferences.
If you wish, you can also choose how web browser cookies are handled by your device via your browser settings. Some devices allow you to control this through your device settings. Each browser and device is different, so check the settings menu of the browser or device to learn how to change your settings and cookie preferences.
Many browser manufacturers provide helpful information about cookie management, including, but not limited to:
Safari (Desktop)or Safari (Mobile)
If you choose not to receive cookies at any time, websites may not function properly, and certain services may not be provided.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from companies that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance.
We have implemented certain administrative, physical, and technical security measures to help protect against loss, misuse, or alteration of your Personal Information. While we use commercially acceptable means to protect your Personal Information, no method of transmission over the Internet is 100 percent secure. As a result, we cannot guarantee the absolute security of your Personal Information. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of Personal Information.
7) International Data Transfers
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. In the unlikely event that we transfer information internationally, we endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer Personal Information that originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your Personal Information, please contact us using the contact methods provided below.
Our Services are not intended for or directed to children under the age of 13. We do not knowingly collect Personal Information directly from children under the age of 13 without parental consent. If we become aware that a child under the age of 13 has provided us with Personal Information, we will delete the information from our records.
9) Links to Other Websites and Services
Our Services may provide links to Internet sites, content, or videos (embedded or direct links) maintained by third parties. We are not responsible for the sites, content, or videos available via those links, and we have not reviewed the privacy practices of those third parties. We encourage you to review the privacy practices of any third-party sites that you choose to access.
10) Changes to this Privacy Notice
We may update this Privacy Notice periodically, noting the date of revision. If we make any material changes in the way we collect, use, and/or disclose Personal Information, we will endeavor to provide you with notice before such changes take effect, such as by posting a prominent notice on the Troutman Pepper website.
This Privacy Notice is governed by and construed in accordance with the laws of the State of Georgia and any action arising out of or relating to this Privacy Notice shall be filed only in state or federal courts located in Fulton County, Georgia. By using our Services, you hereby consent and submit to the personal jurisdiction of such courts for the purpose of litigating any such action.
We welcome your inquiries and comments. Please note, however, that if you are not a client, we may not be able to treat the information that you send us as confidential or privileged. If you wish to contact us regarding legal representation, please contact an attorney in one of our offices near you. You can find a list of our offices and our attorneys on our website (www.troutman.com).
If you have questions about our information practices, please contact us using the following methods:
Mail: Troutman Pepper Hamilton Sanders LLP, Attention: General Counsel, 600 Peachtree Street, Suite 3000, Atlanta, GA, 30308
13) Information for California Residents – California Privacy Rights
California law requires us to disclose the following information with respect to our information practices. If you are a California resident, this section applies to you in addition to the rest of the Privacy Notice.
a) Categories of Personal Information Collected and Sources. Section 1 (Personal Information We May Collect identifies the categories of Personal Information that we may have collected in the preceding 12 months, and the sources from which we obtain such information.
b) Purposes for Collection. We collect and use Personal Information for the business or commercial purposes described in Section 2 (How We Use Personal Information).
c) Categories of Personal Information Disclosed and Categories of Recipients. We may have disclosed any Personal Information collected in the preceding 12 months for purposes consistent with this Privacy Notice, as described in Section 3 (How We Disclose Personal Information).
d) California Privacy Rights. Subject to certain limitations, California residents have the following rights regarding their Personal Information.
Request to Know. You have a right to request that we disclose what Personal Information we have collected about you, including the categories of your Personal Information we have collected, the categories of sources from which such Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing your Personal Information, the categories of third parties to whom we disclose your Personal Information, and the specific pieces of your Personal Information that we maintain.
Request to Delete. You have a right to request that we delete Personal Information that we have collected about you, subject to certain exceptions.
Request to Correct Inaccurate Personal Information. You have a right to request that we correct inaccurate Personal Information that we may maintain about you.
Request to Opt Out of the “Sale” or “Sharing” of Your Personal Information. You have a right to opt out of the “selling” or “sharing” of your Personal Information; however, we do sell or share any Personal Information, including the Personal Information of individuals under 16 years of age.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit the use of your “sensitive personal information” (as defined by applicable law) to certain purposes permitted by law. As noted above, however, Troutman Pepper does not collect sensitive personal information.
Right to No Discrimination. You have a right not to receive discriminatory treatment for the exercise of your privacy rights.
e) Exercising Your California Privacy Rights
How to Submit a Request to Know, Request to Delete, or Request to Correct. You may submit a request by contacting us at email@example.com or 800.255.8752.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may submit a request relating to your Personal Information. To authorize an agent to submit a request on your behalf, please provide written authorization signed by you and your designated agent. You may contact us at firstname.lastname@example.org for additional instructions.
Verification. To protect your privacy, we will take steps to verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to confirm you are the person about whom we collected Personal Information or an authorized representative, or to answer questions regarding your use of our Services or recent interactions with us.
f) Do Not Track Disclosure. Some browsers offer a “Do Not Track” privacy preference. Generally, when a user turns on the “Do Not Track” Signal, their browser sends a message to websites requesting that the user not be tracked. Our websites currently do not respond to “Do Not Track” signals.