Privacy Policy - CA
Weil California Privacy Policy
Last Updated as of January 1, 2025
This privacy policy for California residents (this “CA Policy”) is provided in addition to any other privacy notice provided by Weil Gotshal & Manges LLP (a limited liability partnership incorporated in New York, USA) and our associated entities practicing under the name Weil Gotshal & Manges in other jurisdictions, together referred to as “Weil” or “we,” including the Weil Website Privacy Policy, and explains Weil’s online and offline collection, use, and disclosure of Personal Information relating to residents of the State of California (“consumers” or “you” or “your”) covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and provides information regarding how such California residents can exercise their rights under the CCPA.
This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. If you are a California employee, you will have received a separate privacy notice. This CA Policy is available in alternative formats upon request. Please contact privacy@weil.com or 877-999-9345 to request this CA Policy in an alternative format.
I. OUR COLLECTION, USE, RETENTION AND DISCLOSURE OF PERSONAL INFORMATION
a. Sales and Sharing of Personal Information. We do not sell and have not sold any categories of Personal Information to third parties or shared any categories of Personal Information for the purpose of cross-context behavioral advertising purposes.
b. Collection, Sources and Use of Personal Information. During the 12-month period prior to the “last updated” date of this CA Policy, we have collected and used the following categories of Personal Information from the following sources and for the following business purposes:
Categories of Personal Information |
Sources |
Business Purposes |
Identifiers: including name, contact details (such as address, telephone number, email address and Internet Protocol address); cookies, beacons, pixel tags, mobile ad identifiers and similar technology, and other online identifiers. |
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· To provide services that you reasonably expect from us (“Services”); · For internal auditing and verifications such as verifying the quality and effectiveness of our services (“Auditing”); · For short-term, transient uses necessary for processing data (“Transient Uses”); · To protect our systems, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, prosecuting those responsible, and debugging to identify and repair errors that impair intended functionality (“Security”); and · To comply with our legal obligations, such as in connection with a valid court order, judicial subpoena or regulatory inquiry, and as required by law enforcement agencies, federal or state regulatory agencies, or self-regulatory organizations (“Compliance”). |
Other Identifying Records: including signature, physical characteristics or description; bank account number, other financial information (including accounts and transactions with other institutions); driver’s license or other state ID card number, or passport number; medical information and health insurance information; and verification documentation (including social security number, tax status, income and assets). |
From You; Cookies; Weil; Counterparties; Vendors; and Recruitment. |
Services; Auditing; Transient Uses; Security; Compliance. |
Protected Classifications: including those under California and/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. |
From You; Cookies; Weil; Counterparties; Vendors; and Recruitment. |
Services; Auditing; Transient Uses; Security; Compliance./span> |
Sensory Data: such as the contents of audio or visual recordings. |
From You; Weil; Counterparties; and Vendors. |
Services; Auditing; Transient Uses; Security; Compliance. |
Commercial Data: including your transactions and services purchased. |
From You; Cookies; Weil; Counterparties; Vendors; and Recruitment. |
Services; Auditing; Transient Uses; Security; Compliance. |
Online Activity Data: including your Internet and other electronic network activity information (e.g., browsing history, search history, and information regarding your interaction with websites, applications or advertisements). |
From You; Cookies; Weil; Counterparties; Vendors; and Recruitment. |
Services; Auditing; Transient Uses; Security; Compliance. |
Employment Data: professional or employment-related information such as job title, employer information and work history. |
From You; Cookies; Weil; Counterparties; Vendors; and Recruitment. |
Services; Auditing; Transient Uses; Security; Compliance. |
Education Data: information relating to any school you attended including transcripts or other educational records. |
From You; Cookies; Weil; Counterparties; Vendors; and Recruitment. |
Services; Auditing; Transient Uses; Security; Compliance. |
Inferences: data used to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
From You; Cookies; Weil; Counterparties; Vendors; and Recruitment. |
Services; Transient Uses; Compliance. |
Other Information: data you create or provide to us, including the content of your communications with us. |
From You; Cookies; Weil; Counterparties; Vendors; and Recruitment. |
Services; Auditing; Transient Uses; Security; Compliance. |
c. Sensitive Personal Information. Sensitive Personal Information may include social security numbers, driver’s license numbers, or passport numbers; account credentials; precise geolocation; racial or ethnic origin; religious beliefs; biometric data; personal information concerning a consumer’s health or sex life or sexual orientation; as well as contents of a consumer’s mail, email and text messages. To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect and investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute and/or defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient use; (vi) to perform services necessary for the business; (vii) to verify and maintain the quality and safety of our product or services; and (viii) generally for purposes that do not infer characteristics about you.
d. Retention of Personal Information. We retain Personal Information in compliance with applicable laws, and for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected.
e. Disclosures of Personal Information for Business Purposes. We have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes during the 12-month period prior to the “last updated” date of this CA Policy:
Business Purposes |
Categories of Recipients |
Categories of Personal Information |
Services. |
|
Identifiers; Other Identifying Records; Protected Classifications; Sensory Data; Commercial Data; Online Activity Data; Employment Data; Education Data; Inferences; and Other Information. |
Auditing. |
Service Providers; Advisors; Counterparties; Clients. |
Identifiers; Other Identifying Records; Protected Classifications; Sensory Data; Commercial Data; Online Activity Data; Employment Data; Education Data; Inferences; and Other Information. |
Transient Uses. |
Service Providers. |
Identifiers; Other Identifying Records; Protected Classifications; Sensory Data; Commercial Data; Inferences; Online Activity Data. |
Security. |
Service Providers; Advisors; Government Entities. |
Identifiers; Other Identifying Records; Protected Classifications; Sensory Data; Commercial Data; Online Activity Data; Employment Data; Education Data; Inferences; and Other Information. |
Compliance. |
Service providers; advisors; counterparties; clients; Government Entities. |
Identifiers; Other Identifying Records; Protected Classifications; Sensory Data; Commercial Data; Online Activity Data; Employment Data; Education Data; Inferences; and Other Information. |
II. YOUR CALIFORNIA PRIVACY RIGHTS
a. Your CCPA Privacy Rights. You have certain choices regarding our use and disclosure of your Personal Information, as described below.
i. Know: You have the right to request, twice in a 12-month period, that we provide (1) certain information about the (i) categories of Personal Information we have collected about you; (ii) categories of sources from which the Personal Information is collected; (iii) business or commercial purpose for collecting your Personal Information; and (iv) categories of third parties with whom we have shared your Personal Information; and/or (2) the specific pieces of Personal Information we have collected, used, and disclosed about you.
ii. Deletion: You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
iii. Correction: You have the right to request that we correct or amend certain Personal Information we maintain about you if it is inaccurate.
iv. Limit: You have the right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. If Weil collects any sensitive personal information, we will use it only for purposes listed above in Section I(c). As such, any Sensitive Personal Information that we collect does not come within this right to limit use.
v. Opt Out: You have the right to opt out of the sale of your Personal Information and the sharing of your Personal Information for cross-context behavioral advertising. Weil does not engage in such activities, so the Personal Information we collect does not come within this opt-out right.
vi. Non-Discrimination: You have the right to not experience discriminatory treatment, and we will not discriminate against you, because you have exercised any California consumer privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
b. How to Submit a Request. You may submit a request by using one of the following methods.
Call: 877-999-9345
Email: privacy@weil.com
c. Verifying Your 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 we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
i. Consumer Verification. If you request to know, access, delete, and/or correct your Personal Information, we may require you to provide any of the following information: address, date of birth, state or country of residence, telephone number, email address, or details of a transaction. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.
ii. Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide us with a copy of the authorized agent’s written permission to do so, and (2) verify your own identity with us (as described above).
d. Additional California Privacy Disclosures
i. Do Not Track Signals. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
ii. Shine the Light Notice. California residents may request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in Section II(b), above.
CALIFORNIA EMPLOYEE PRIVACY POLICY
This is the privacy policy for California employees, job applicants, and independent contractors (“CA Employee Privacy Policy”) of Weil Gotshal & Manges LLP (a limited liability partnership incorporated in New York, USA) and our associated entities practicing under the name Weil Gotshal & Manges in other jurisdictions (together, “Weil” or “we”). This CA Employee Privacy Policy governs how Weil collects, processes, and uses Personal Information (as defined below) relating to employees, job applicants, contractors, and other individuals with whom we may enter into an employment relationship in the State of California (collectively, “you”) and your rights with respect to your Personal Information.
This Policy was last updated as of January 1, 2025, and it should be read in conjunction with, as applicable, your terms of employment and other Weil policies and notices.
1. DEFINITIONS
A. Business Purposes means the purposes for which Personal Information may be used by Weil in the course of providing our services and operating our business (including conducting administrative, financial, and regulatory, payroll and business development activities).
B. Personal Information means any information that identifies, could be used to identify or is otherwise associated with an individual person, which is in the possession of, or is likely to come into the possession of, Weil (or its representatives or service providers), and includes the definition of Personal Information under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”).
2. OUR COLLECTION AND SOURCES OF PERSONAL INFORMATION
In connection with your employment at Weil and our provision of benefits and services to you, as well as in connection with our provision of services to our clients and compliance with our legal obligations, in the past twelve (12) months, we have collected the following categories of Personal Information from you directly and from additional sources identified as follows, depending on your role at Weil:
- Employment or Partnership Data. As it relates to your employment with Weil, we collect from you, and may create about you, details of your employment; details of your salary and benefits; and, as applicable, information relating to applications you make for other positions with us. We may collect from you, from other employees, consultants and other professionals we may engage, and may create about you, to the extent applicable, data concerning your appraisals and performance reviews; details of your performance management/improvement plans; information regarding your work output; details of your time and attendance records; information about grievances raised by or involving you; and information about conduct and/or other disciplinary matters raised by or involving you. We may collect, from you or from outside sources, details of your use of business-related social media, such as LinkedIn. We also may collect from you, from other employees, consultants, and other professionals we may engage, and may create about you, details in references about you that we provide to others.
- Identifiers. As it relates to your employment with Weil (including to allow us to provide benefits and services to you related to your employment), and to comply with our legal obligations, we may collect directly from you identifiers such as your name, postal address, Internet Protocol (IP) address, email address, driver’s license number, passport number, social security number, tax status, bank account information and other financial information, and other similar identifiers.
- Communications Data. In connection with providing benefits and services to you related to your employment and providing services to our clients, in order to protect our business, employees and clients, and in order to protect and defend our legal rights, during the recruitment process, when you commence employment with Weil, and as you may provide updates from time to time, we collect directly from you communications-related data such as your name and contact details (i.e., home and email address, home and mobile phone numbers). We also collect the content of all emails and other electronic communications you send or receive from any Weil account and/or device and we may, in certain circumstances, collect the content of electronic communications related to your employment with us you send or receive from a personal account or device.
- Recruitment Data. In order to hire and onboard you, as well as in connection with providing benefits and services to you related to your employment and providing services to our clients, in order to protect our business, employees and clients, and in order to protect and defend our legal rights, during the recruitment process, and as we may retain during your employment with Weil, we collect directly from you and from other sources (including recruiters, headhunters, social media and other online platforms), information about your prior employment history, references, and organizational affiliations. As part of the recruitment process, we may engage third-party service providers to run background checks and collect criminal records, and other related data from and about you.
- Education Data. In order to hire and onboard you, as well as in connection with providing benefits and services to you related to your employment, and providing services to our clients, during the recruitment process, and as we may retain during your employment with Weil, we collect directly from you and from other sources (including schools, recruiters, headhunters, social media and other online platforms) your education records, which may include information that is not publicly available personally identifiable information under the Family Educational Rights and Privacy Act.
- Audio or Visual Data. In order to protect our business, premises, Information Technology (IT) systems, and our employees and clients, and in connection with providing benefits and services to you related to your employment, and to provide services to our clients, we collect directly from you, or through third party service providers that we engage, your photograph, audio or video recordings of you, and information collected through our security systems such as video surveillance (“CCTV”) and facility entry systems. We may record and/or monitor electronic communications (including email and telephone) to the extent permitted by applicable law.
- Financial Data. In connection with the administering of necessary financial transactions associated with your employment with Weil (including processing payroll, and processing benefits enrollment and claims), we may collect from you, from our Legal Personnel and Human Resources administrators, and from financial service providers with which we engage, and may create about you, banking and insurance information, tax information, and details of your 401(k) plan, and all information necessary to implement and administer these arrangements.
- Family Data. In connection with providing benefits and services to you related to your employment (including providing insurance and administering other benefits such as vacation and medical leave), as you may provide to us during the recruitment process and/or during your employment with Weil, and as you may provide updates from time to time, and as we may collect through benefit administrators, and healthcare professionals that you or we engage, we may collect from you details relating to your spouse/partner and any dependents (e.g., name, relationship, age, gender, address, email address, and phone numbers).
- Protected Characteristics. In connection with providing benefits and services to you related to your employment (including providing insurance and administering other benefits such as medical leave), in order to protect our business, employees and clients, and in order to protect and defend our legal rights, as you may provide to us during the recruitment process and/or during your employment with Weil, and as you may provide updates from time to time, we may collect directly from you, or through third party service providers that we engage, data that contain protected classifications under California or federal law, including your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information; your age, gender, racial or ethnic origin, sex and sexual orientation, religious or similar beliefs; and, where applicable, and any external appointments you may hold.
- Health-Related Data. In connection with providing benefits and services to you related to your employment (including providing insurance and administering other benefits such as medical leave), in order to protect our business, employees and clients, and in order to protect and defend our legal rights, we may collect from you, as well as from benefit administrators and healthcare professionals that you or we engage, data pertaining to your sickness and absence records, including sensitive personal information regarding your physical and/or mental health.
- IT and Online Data. In order to protect our business, premises, IT systems, and our employees and clients, in order to protect and defend our legal rights, and in connection with providing benefits and services to you and to provide services to our clients, we collect from you, create about you, and/or collect from other sources (such as third party software that we use for our Business Purposes) information about your use of our IT, communication and other systems such as swipe card systems, time management systems, technical systems (such as our computer networks and connections), remote access systems, email, telephones, voicemail, mobile phone records, web searches, and our data servers; and, in some cases, other monitoring information such as CCTV images.
- Inferences. As it relates to your employment, in connection with providing benefits and services to you, conducting appraisals and performance reviews, processing grievances and/or disciplinary matters raised by or involving you, and applications you make for other positions with us, and in the course of providing services to our clients, we may create about you certain inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.
SENSITIVE PERSONAL INFORMATION
As described above, some of the Personal Information we collect from and about you is classified as Sensitive Personal Information under California law (which includes information such as identifiers like social security numbers; financial account information; racial or ethnic origin and religious beliefs; the contents of electronic communications).
We collect and use Sensitive Personal Information without the purpose of inferring characteristics about you. We will not use or disclose your Sensitive Personal Information for purposes other than (i) to provide benefits and services that you reasonably expect from us, (ii) to prevent, detect and, investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute and/or defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient use; (vi) to perform services necessary for the business; (vii) to verify and maintain the quality and safety of services controlled by Weil; and (viii) generally for purposes that do not infer characteristics about you.
RETENTION
The categories of Personal Information listed above are collected, used, retained, and shared by Weil and designated third-parties only as necessary and proportionate to achieve the purposes disclosed to you in this Privacy Policy or otherwise disclosed at or before the time of collection. We will not retain any category of your Personal Information for longer than is reasonably necessary for each disclosed purpose.
We determine the period for retaining your Personal Information with regard to the period for which storage is necessary to achieve the purpose for collecting the data, and our operational and legal requirements (which includes responding to legal claims or regulatory requests).
3. OUR DISCLOSURE OF YOUR FINANCIAL INFORMATION
Weil does not sell or otherwise disclose your Personal Information to third parties in exchange for monetary or other valuable benefit and does not share your Personal Information with third parties for the purpose of targeted advertising or cross-context behavioral advertising. In order to facilitate our business operations, we may share anonymous or aggregated data with third parties such as service providers. We have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes in the past twelve (12) months:
Business Purposes |
Categories of Personal Information |
Categories of Recipients |
Providing services to you (including processing payroll, and processing benefits enrollment and claims), as well as providing services to our clients. |
Employment or Partnership Data; Identifiers; Communications Data; Recruitment Data; Education Data; Audio or Visual Data; Financial Data; Family Data; Protected Characteristics; Inferences; Health-Related Data; IT and Online Data. |
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Auditing related to a current interaction with you (including determining employment eligibility and compensation, processing leaves of absence, and processing disability claims). |
Employment or Partnership Data; Identifiers; Communications Data; Audio or Visual Data; Financial Data; Family Data; Protected Characteristics; Health-Related Data. |
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Short-term, transient uses. |
Identifiers; IT and Online Data. |
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Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. |
Employment or Partnership Data; Identifiers; Communications Data; Audio or Visual Data; IT and Online Data. |
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Debugging to identify and repair errors that impair existing intended functionality. |
Identifiers; Communications Data; Audio or Visual Data; IT and Online Data. |
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Undertaking internal research for technological development and demonstration, such as providing workforce metrics and analysis. |
Employment or Partnership Data; Identifiers; Recruitment Data; Education Data; Protected Characteristics; IT and Online Data. |
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Undertaking activities to verify or maintain the quality of our services, including vendor training and investigating claims into alleged unlawful conduct (such as workplace investigations). |
Employment or Partnership Data; Identifiers; Communications Data; Recruitment Data; Financial Data; Family Data; Protected Characteristics; Health-Related Data; IT and Online Data; Inferences. |
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To comply with legal obligations such as in connection with a valid court order, judicial subpoena or regulatory inquiry; and as required by law enforcement agencies, federal or state regulatory agencies, or self-regulatory organizations. |
Employment or Partnership Data; Identifiers; Communications Data; Recruitment Data; Education Data; Audio or Visual Data; Financial Data; Family Data; Protected Characteristics; Health-Related Data; IT and Online Data; and Inferences. |
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4. YOUR CALIFORNIA PRIVACY RIGHTS
a. Your Rights. You may have certain legal rights in relation to our use and disclosure of your Personal Information, which may include:
i. Know: The right to request, twice in a 12-month period, information about (A) the categories of Personal Information we have collected about you and sources from which the Personal Information is collected, the business or commercial purpose for collecting your Personal Information, and the categories of third parties to whom we have disclosed your Personal Information; and/or (B) the specific pieces of Personal Information we have collected, used, and disclosed about you during the 12 months preceding your request.
ii. Deletion: The right to request, subject to certain legal exemptions, that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
iii. Correction: The right to request that we correct or amend certain Personal Information we maintain about you, if it is inaccurate.
iv. Limit: The right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. We use Sensitive Personal Information only for purposes listed above in Section 2 and, as such, any Sensitive Personal Information that we collect does not come within the right to limit use.
v. Opt Out: The right to opt out of the sale of your Personal Information to third parties and/or the sharing of your Personal Information for the purpose of cross-context behavioral advertising. We do not sell or share your Personal Information and, as such, the Personal Information we collect from or about you does not come within this right.
vi. Non-Discrimination: You have the right not to experience discriminatory treatment, and we will not discriminate against you, because you have exercised any California privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
b. How to Submit a Request. You may submit a request by using one of the following methods:
Email: californiaprivacy@weil.com
Phone: 877-999-9345 (toll-free)
c. Verification. To help protect your privacy and maintain security, we may take additional steps to verify your identity before complying with your request. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
i. Consumer Verification. When you submit a request, we may require you to provide additional information about yourself in order to verify that the request is coming from you. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request.
ii. Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent written permission (e.g., via a notarized letter) to do so, and (2) verify your own identity directly with us (as described above), and confirm with us that you provided the authorized agent permission to submit the request.
5. CONTACT
If you have any questions or concerns about this CA Policy, you may contact californiaprivacy@weil.com.