Foley & Lardner LLP Website Privacy
Addendum for California Residents

This Website Privacy Addendum for California Residents (the “California Website Privacy Addendum”) supplements the information contained in Foley’s Website Privacy Notice (the “Website Privacy Notice”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this California Website Privacy Addendum to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this California Website Privacy Addendum. 

Note that this California Website Privacy Addendum does not apply employment-related personal information collected from our California-based employees, job applicants, contractors, or similar individuals. Please contact your local human resources department if you are a California employee and would like additional information about how we process your Personal Information.

Information We Collect or Have Collected

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, Foley’s Website collects and has collected the following categories of Personal Information from its Website users within the last twelve (12) months:

Category	Applicable Pieces of Personal Information Collected
A. Identifiers.	A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name. Some Personal Information included in this category may overlap with other categories.
D. Commercial information.	Records of products or services purchased, obtained, or considered (such as blog posts that you subscribe to or events that you attend).
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
I. Professional or employment-related information.	Current job title.

Personal Information does not include:

• Publicly available information from government records.
  
• Deidentified or aggregated consumer information.

Use of Personal Information

We may use or disclose the personal information we collect and, over the prior twelve (12) months, have used, or disclosed the personal information we have collected, for the business or commercial purposes listed in the “How We Use Your Information” section of our Website Privacy Notice. Foley will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sources of Personal Information

Except as otherwise noted below, Foley obtains the categories of Personal Information listed above from the categories of sources described in the “Personal Information We Collect About You and How We Collect It” section of our Website Privacy Notice. 

Sharing Personal Information

Foley may disclose your Personal Information to a third party for a business or commercial purpose (not including “sales” of your Personal Information as discussed below). When we disclose Personal Information for a business or commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. 

Disclosures of Personal Information for a Business or Commercial Purpose

We share your Personal Information with the categories of third parties described in our Privacy Notice. In the preceding twelve (12) months, Foley has disclosed the following categories of Personal Information for a business or commercial purpose: 

A. Identifiers: Service providers; business partners; and subsidiary organizations of Foley. 

B. California Customer Records Personal Information categories: Service providers; business partners; and subsidiary organizations of Foley.

C. Commercial information: Service providers; business partners; and subsidiary organizations of Foley.

D. Internet or other similar network activity: Internet cookie information recipients, such as analytics services.

E. Professional or employment-related information: Service providers; business partners; and subsidiary organizations of Foley.

Sales of Personal Information 

Foley does not sell your information as defined under the CCPA. 

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Foley disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of Personal Information we collected about you.
  
• The categories of sources for the Personal Information we collected about you.
  
• Our business or commercial purpose for collecting that Personal Information.
  
• The categories of third parties with whom we share that Personal Information.
  
• The specific pieces of Personal Information we collected about you (also called a data portability request).
  
• If we sold or disclosed your Personal Information for a business purpose a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. 

Deletion Request Rights 

You have the right to request that Foley delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

1. Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you (if any).
   
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
   
3. Debug products to identify and repair errors that impair existing intended functionality.
   
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
   
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
   
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
   
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
   
8. Comply with a legal obligation.
   
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: 

• Calling us at +1 (833) 701-1071.
• Emailing us at [email protected]. 
• Submitting a form in person at one of our offices. This form is available at one of these locations.

If you (or your authorized agent) submit a request to delete your information online, we will use a two-step process in order to confirm that you want your personal information deleted. This process may include verifying your request through your email address on record.

If you fail to make your submission in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above, or provide you with information on how to submit the request or remedy any deficiencies with your request. 

Only you, or your agent that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, see Authorized Agents below. We may request additional information so we may confirm a request to delete your personal information. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. 
  
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us or otherwise be our client. 

Authorized Agents

You may authorize your agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State. You may also provide your authorized agent with power of attorney to exercise your rights. If you authorize an agent, we may require that your agent provide proof that they have been authorized exercise your rights on your behalf. We may request that your authorized agent submit proof of identity. We may deny a request from your agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights. 

Response Timing and Format

We will respond to a verifiable consumer request within ten (10) days of its receipt. We will generally process these requests within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not, as a result of you exercising any of your CCPA rights:

• Deny you services.
  
• Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
  
• Provide you a different level or quality of services.
  
• Suggest that you may receive a different price or rate for services or a different level or quality of services.

Changes to This California Website Privacy Addendum

Foley & Lardner LLP reserves the right to amend this GDPR Website Privacy Addendum at our discretion and at any time and at any time and as described in our Website Privacy Notice. When we make changes to this GDPR Website Privacy Addendum, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this California Website Privacy Addendum, the ways in which Foley collects and uses your information described in this California Website Privacy Addendum or in the Website Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as described in our Website Privacy Notice.