Foley Alumni Network

Foley & Lardner LLP Alumni Portal Privacy Notice

Foley & Lardner LLP Alumni Portal Privacy Addendum for California Residents

Foley & Lardner LLP Alumni Portal Privacy Notice

Last modified: [January 9, 2024]

Introduction

Foley & Lardner LLP (“Foley” or “we” or “us”) respect your privacy and are committed to protecting it through our compliance with this policy.

This Alumni Portal Privacy Notice (our “Portal Privacy Notice”) describes the types of information we may collect from you or that you may provide when you visit the website alumni.foley.com (the “Portal”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to Personal Data (as defined below) that we collect:

on our Portal;
in email, text, and other electronic messages between you and our Portal; and
when you follow a link on one of our social media accounts, such as Facebook, Twitter, and LinkedIn.

It does not apply to Personal Data collected by:

us offline or through any other means, including on any other website operated by Foley or any third-party;
us or any of our affiliates or subsidiaries related to your or any other individual’s current, past, or future human resources records with us (other than as used by the Portal as described in this Portal Privacy Notice); or
any third party, including through any application or content (including advertising) that may link to the Portal.

Please read this policy carefully to understand our policies and practices regarding your Personal Data and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Portal. By accessing or using this Portal, you agree to this Portal Privacy Notice. This Portal Privacy Notice may change from time to time (see Changes to Our Portal Privacy Notice). Your continued use of this Portal after we make changes is deemed to be acceptance of those changes, so please check this Portal Privacy Notice periodically for updates.

Children Under the Age of 18 or Under the Legal Age to Form a Binding Contract in Your Jurisdiction

Our Portal is not intended for children under 18 years of age or the legal age to form a binding contract in your jurisdiction, whichever is higher. No one under this age may provide any information to or on the Portal. We do not knowingly collect Personal Data from children under this age. If you are under this age, do not use or provide any information on our Portal or on or through any of its features or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received Personal Data from a child under this age without verification of parental consent, we will delete that information. If you believe we might have any information from a child under this age, please contact us at PrivacyOfficer@foley.com.

Personal Data We Collect About You and How We Collect It

Generally

We collect several types of information from and about users of our Portal (“Personal Data”):

by which you may be personally identified, such as name, e-mail address, company name, title, or any other information that you may provide in a message;
that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Portal, error information, clickstream data, and other communication data and the resources that you access and use on the Portal; and/or
about your internet connection, the equipment you use to access our Portal and usage details.

We collect this information:

directly from you when you provide it to us;
information that we create about you as a staff member, associate, partner, or other employee with us that we incorporate into the Portal as described below;
automatically as you navigate through the Portal.

Information You Provide to Us

The information we collect on or through our Portal are:

information that you provide by filling in forms on our Portal. This includes information provided at the time of sending us an inquiry through our Contact Us page or subscribing to a blog;
information you provide when you report a problem with our Portal;
your responses to surveys that we might ask you to complete for research purposes;
records and copies of your correspondence (including email addresses), if you contact us; and
your search queries on the Portal.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Portal or transmitted to other users of the Portal or third parties, such as your current resume, status updates, education, chat messages, and other similar information (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Portal with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Portal, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

details of your visits to our Portal as described above; and
Information about your computer and internet connection, i.e. your IP address, operating system, and browser type.

The information we collect automatically includes Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Portal and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
understand our who the audience and users of our Portal are, including through identifying the company to which our Portal visitors belong;
store information about your preferences, allowing us to customize our Portal according to your individual interests;
speed up your searches; and
recognize you when you return to our Portal.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our Portal may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Portal. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Portal. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Portal. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu and more information about the specific cookies we use on the Portal by clicking the “cookies” link at the bottom of the Portal.
Session Cookies. Our use of cookies also includes “session cookies.” Each time you access the Portal, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Portal and track which pages of the Portal you access. Session cookies are required to use the Portal.
Web Beacons. Pages of our Portal and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Portal Interaction and Performance Monitoring Tools. Our Portal may also use interaction and/or performance monitoring tools (sometimes call tracking scripts, analytics tools, session replay tools, or heatmap tools). These tools execute code in your web browser to help us collect data about your use of and interactions with the pages and content on our Portal. This may include recording your mouse movements, keystrokes, navigation pathways, other actions that you take our Portal, and information automatically transmitted from your web browser to our Portal such as information about your operating system, computer hardware, and browser preferences. By using our Portal, you hereby consent to our recording of your mouse movements, keystrokes, navigation pathways, other actions that you take or communications you may have with our Portal and other use of such tools.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

to present our Portal and its contents to you;
to provide you with information that you request from us;
to support, develop, troubleshoot, and debug our Portal;
to create, maintain, customize, and secure your alumni portal account with us;
to provide you with notices about your account;
to allow you to participate in the interactive features of our Portal (including communicating with other users and reading and posting User Contributions);
to personalize your Portal experience and to deliver content offerings relevant to your interests;
to maintain the safety, security, and integrity of our Portal;
for internal testing, research, analysis, and development, including to develop and improve our Portal (and other websites) and to develop, improve, or demonstrate various resources we offer to our current and former employees and partners;
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
debugging to identify and repair errors that impair existing intended functionality;
to carry out our obligations and enforce our rights in our terms of use;
to notify you about changes to our Portal;
in any other way we may describe when you provide the information. For example, if you share your name and contact information to send us an inquiry about our services or any other question, we will use that personal information to respond to your inquiry;
to fulfill any other purpose for which you provide it; and
for any other purpose with your consent.

With your consent, we may also use your Personal Data to contact you about events that may interest you, such as conferences, seminars, and other similar events. If you do not want us to use your Personal Data in this way, simply check the relevant box located on the form on which we collect your data or contact us at the Contact Information below. For more information, please see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Portal Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Portal Privacy Notice:

to our subsidiaries and affiliates;
to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services, including PeoplePath, which has developed and hosted this Portal for us;
to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Foley’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Foley about our Portal’s users is among the assets transferred;
to fulfill the purpose for which you provide it. For example, if you provide your personal information to subscribe to a blog post, we will use that information to send you new blog posts;
to other users of our Portal. In particular, we disclose the following types of information to all users of our Portal: (a) basic profile information, such as name and picture; (b) current professional information, such as organization and primary industry; (c) professional contact information (which may be hidden by you upon request); (d) Foley history, such as the date you joined and departed Foley, your office location, position, and other similar information; (e) education; (f) personal contact information (only upon request). You may also optionally share the following information with other users: (1) personal contact information (including personal email address);
to enforce our rights;
for any other purpose disclosed by us when you provide the information; and
with your consent.

We may also disclose your Personal Data:

to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our terms of use and other agreements; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Foley, our customers, or others.

Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

Tracking Technologies and Advertising. You can enable or disable categories of non-essential cookies through our cookie consent manager, which you can access through the “cookies” link on the Portal. You can also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Portal may then be inaccessible or not function properly.
Communications from Foley. We will only use your email address to send you information you request when you have configured your account to do so. If we have sent you some communications, you may click the unsubscribe link at the bottom of the email to be omitted from future email distributions.

California residents may have additional personal information rights and choices. Please see Jurisdiction Specific Rights for more information.

Accessing, Correcting, and Deleting Your Information

You may contact us at the Contact Information below to request access to, correct, or delete any Personal Data that we have collected about you. If you are subscribed to certain communications from the Portal and your role as an alumni of Foley, we cannot delete your Personal Data without also unsubscribing you from receiving those communications. We may not accommodate a request to change your Personal Data if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Jurisdiction-Specific Privacy Rights

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Portal Privacy Notice.

Your California Privacy Rights

You have the additional rights described in the California Portal Privacy Addendum.

Do Not Track Signals and Global Privacy Control Signals

Our Portal may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers or operating systems permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

Our Portal[s] are designed to honor the GPC Signal and/or we may limit the Personal Data or other information we collect and how we use your Personal Data or other information based upon whether such a signal is transmitted by your browser or device and received by us.

Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Portal. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Portal.

Changes to Our Portal Privacy Notice

We may change this Portal Privacy Notice at any time. It is our policy to post any changes we make to our Portal Privacy Notice on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you through a notice on the Portal’s home page. The date this Portal Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Portal and this Portal Privacy Notice to check for any changes.

Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Portal Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below.

To Contact Foley

Foley & Lardner LLP

Attn: Office of the General Counsel/Privacy Officer

321 N. Clark Street, Suite 2800

Chicago, IL 60654

United States

1(312)832-4500

PrivacyOfficer@foley.com

Foley & Lardner LLP

Alumni Portal Privacy Addendum for California Residents

Effective Date: January 1, 2020

Last Reviewed on: January 9, 2024

This Portal Privacy Addendum for California Residents (the “California Alumni Portal Privacy Addendum”) supplements the information contained in Foley’s Alumni Portal Privacy Notice (the “Alumni Portal Privacy Notice”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”) who use the Alumni Portal as a member of the Foley Alumni community. We adopt this California Alumni Portal Privacy Addendum to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this California Alumni Portal Privacy Addendum.

Note that this California Alumni Portal Privacy Addendum does not apply employment-related personal information collected from our California-based employees, job applicants, contractors, or similar individuals that is maintained by our human resources department and not collected or used as part of your status as an alumni of Foley. Please contact your local human resources department if you are a California employee and would like additional information about how we process such Personal Data.

Information We Collect or Have Collected

Our Portal 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 Data”). In particular, Foley’s Portal collects and has collected the following categories of Personal Data from its Portal users within the last twelve (12) months:

Category	Applicable Pieces of Personal Data Collected
Identifiers.	A real name, alias, unique personal identifier, online identifier, Internet Protocol address, personal and/or work email address, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, personal and/or work address and telephone number, current employment (such as your current employer, the type of employer, primary industry of your employer, and your job title), employment history (including the dates you joined and departed Foley, your last Foley office location, your last position at Foley, your last Foley department, and whether or not you were also a summer associate at Foley, and other prior employers and job titles at those employers). Some Personal Data included in this category may overlap with other categories.
Commercial information.	Information about how you would like to support other alumni and your professional relationships with Foley alumni in the past and how you would otherwise be interested in getting involved in the Foley Alumni Network.
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Sensory Data	We may collect your photograph, if you decide to provide it.
Professional or employment-related information.	Current employer, the type of employer, primary industry of your employer, and your job title; dates you joined and departed Foley, your last Foley office location, your last position at Foley, your last Foley department, and whether or not you were also a summer associate at Foley; other prior employers and job titles.
Sensitive Personal Information	Complete account access credentials (usernames combined with required access/security code or password).

Personal Data does not include:

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

Use of Personal Data

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 Alumni Portal 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 Data

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

Sharing Personal Data

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

Disclosures of Personal Data for a Business or Commercial Purpose

We share your Personal Data 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 Data for a business or commercial purpose (note that some disclosures to other users of the Portal may be subject to your privacy and disclosure settings):

Identifiers: Service providers; business partners; other users of the Portal; social media companies; and subsidiary organizations of Foley.

California Customer Records Personal Data categories: Service providers; business partners; other users of the Portal; social media companies; and subsidiary organizations of Foley.

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

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

Sensory Data: Service providers; business partners; other users of the Portal; social media companies; and subsidiary organizations of Foley.

Professional or employment-related information: Service providers; business partners; other users of the Portal; social media companies; and subsidiary organizations of Foley.

Sensitive Personal Information:

Usernames and Passwords: Service providers; business partners; and subsidiary organizations of Foley.

We disclose your Personal Data to the categories of third parties listed above for the following business or commercial purposes:

Helping to ensure security and integrity of the Portal and or IT infrastructure to the extent the use of the Personal Data is reasonably necessary and proportionate for these purposes.
Debugging to identify and repair errors that impair existing intended functionality.
Performing services on behalf of us, including maintaining or servicing accounts, providing customer service, verifying customer information, providing analytic services, providing storage, or providing similar services on behalf of us.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

In addition to the above, we may disclose any or all categories of Personal Data to any third-party (including government entities and/or law enforcement entities) as necessary to:

comply with federal, state, or local laws, or to comply with a court order or subpoena to provide information;
comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law;
comply with certain government agency requests for emergency access to your Personal Data if you are at risk or danger of death or serious physical injury; or
exercise or defend legal claims.

No Selling or Sharing of Personal Data

Sales of Personal Data

In the previous twelve (12) months Foley has neither “sold” nor “shared” any Personal Data, and no actual knowledge that we either “sell” or “share” Personal Data from children under the age of 16, as defined under the CCPA.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CCPA Privacy Rights.

Right to Know. You have the right to request that Foley disclose certain information to you about our collection and use of your Personal Data over the past 12 months (a “Right to Know” Consumer Request). This includes: (a) the categories of Personal Data we have collected about you; (b) the categories of sources from which that Personal Data came from; (c) our purposes for collecting this Personal Data; (d) the categories of third parties with whom we have shared your Personal Data; and (e) if we have “sold” or “shared” or disclosed your Personal Data, a list of categories of third parties to whom we “sold” or “shared” your Personal Data, and a separate list of the categories of third parties to whom we disclosed your Personal Data to. You must specifically describe if you are making a Right to Know request or a Data Portability Request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
Access to Specific Pieces of Information (Data Portability). You also have the right to request that Foley provide you with a copy of the specific pieces of Personal Data that we have collected about you, including any Personal Data that we have created or otherwise received from a third-party about you (a “Data Portability” Consumer Request). If you make a Data Portability Consumer Request electronically, we will provide you with a copy of your Personal Data in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Data to another third-party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. In response to a Data Portability Consumer Request, we will not disclose your account password or security question or answers. We will also not provide information if the disclosure would create a substantial, articulable, and unreasonable risk to your Personal Data, your account with Foley, or the security of our systems or networks. We will also not disclose any Personal Data that may be subject to another exception under the CCPA. If we are unable to disclose certain pieces of your Personal Data, we will describe generally the types of personal information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
Correction. You have the right to request that we correct any incorrect Personal Data about you to ensure that it is complete, accurate, and as current as possible. You may review and correct some Personal Data about yourself by logging into the Portal and visiting your “Account” page. You may also request that we correct the Personal Data we have about you as described below under Exercising Your CCPA Privacy Rights. In some cases, we may require you to provide reasonable documentation to show that the Personal Data we have about you is incorrect and what the correct Personal Data may be. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect or if the Personal Data is subject to another exception under the CCPA.
Deletion. You have the right to request that Foley delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Consumer Request (see Exercising Your CCPA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies pursuant to the CCPA. Some exceptions to your right to delete include, but are not limited to, if we are required to retain your Personal Data to provide you the goods and services for which we collected the Personal Data or otherwise perform under a contract with you (such as our terms of use), to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We may also retain your Personal Data for other internal and lawful uses that are compatible with the context in which we collected it.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not do any of the following as a result of you exercising your CCPA rights: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Privacy Rights

To exercise the rights described above, please submit a request (a “Consumer Request”) to us by either:

Calling us at +1 (833) 701-1071.
Emailing us at PrivacyOfficer@foley.com.
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 Consumer 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, calling you on your phone number of record (which may include an automated dialer), sending you a text message and requesting that you text us a confirmation, or sending a confirmation through U.S. Mail. By making a Consumer Request, you consent to us contacting you in one or more of these ways.

If you fail to make a Consumer Request 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 an Authorized Agent that you authorize to act on your behalf, may make a Consumer Request related to your Personal Data. To designate an authorized agent, see Authorized Agents below.

All Consumer Requests must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an Authorized Agent of such a person. This may include, but is not limited to:
- Verifying information you provide against information we have already collected about you, such as your email address, information about your position at Foley, and other similar information.
- Verifying your identity through contacting you through other channels we have on file, such contacting you at your email address or phone number.
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 Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you or the individual for whom you are making the request as their Authorized Agent.

Making a verifiable consumer request does not require you to create an account with us or otherwise be our client. However, we do consider requests made through your password protected account to be sufficiently verified when the request relates to Personal Data associated with that specific account.

We will only use Personal Data provided in a Consumer Request to verify the requestor’s identity or authority to make the request.

Authorized Agents

You may authorize your agent to exercise your rights under the CCPA on your behalf by providing them with power of attorney to exercise your rights in accordance with applicable laws (an “Authorized Agent”). We may require that your Authorized Agent provide proof of their own identity and that they have been authorized exercise your rights on your behalf. We may deny a request from your Authorized 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.

In response to a Right to Know or Data Portability Consumer Request, we will provide you with all relevant information we have collected or maintained about you on or after January 1, 2022, unless an exception applies. The response we provide will also explain the reasons we cannot comply with a Consumer Request, if applicable. For Data Portability Consumer Request, we will select a format to provide your Personal Data 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 Consumer Request unless it is excessive, repetitive, or manifestly unfounded. We reserve the right to consider more than two (2) total Right to Know or Data Portability Consumer Requests (or combination of the two) in a twelve (12) month period to be repetitive and/or excessive and require a fee. If we determine that the Consumer Request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Limiting the Use of Sensitive Personal Information

As further described below, we do not use or disclose your Sensitive Personal Information for any purpose other than the following:

to perform the services or provide the goods reasonably expected by an average Consumer who requests such goods or services;
to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted Sensitive Personal Information, provided that our use of your Sensitive Personal Information is reasonably necessary and proportionate for such purposes;
to resist malicious, deceptive, fraudulent, or illegal actions directed at Foley and to prosecute those responsible for those actions, provided that our use of your Sensitive Personal Information is reasonably necessary and proportionate for this purpose;
to ensure the safety of natural persons, provided that our use of your Sensitive Personal Information is reasonably necessary and proportionate for this purpose;
for short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that the Sensitive Personal Information is not disclosed to another third-party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
to perform services on behalf of us, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us; and
to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us.

Because we only use your Sensitive Personal Information for the above permitted purposes, we do not provide you with a right to limit the use of your sensitive personal information at this time.

Personal Data Retention Periods

Foley will retain your Personal Data for the entire time that you are a member of the Foley Alumni Network. After this period, we may retain your Personal Data for three (3) years, or for any of the reasons listed below, whichever is longer. However, we may retain any or all categories of Personal Data when your information is subject to one of the following exceptions:

when stored in our backup and disaster recovery systems. Your Personal Data will be deleted when the backup media your Personal Data is stored on expires or when our disaster recovery systems are updated;
when necessary for us to exercise or defend legal claims;
when necessary to comply with a legal obligation;
when stored in the same document or record with other Personal Data. Your Personal Data will be deleted upon the expiration of the last exception that applies to such document or record; or
when necessary to help ensure the security and integrity of our Website and IT systems.

Your Personal Data will be deleted when we no longer require your Personal Data for any of the above purposes.

Changes to This California Alumni Portal Privacy Addendum

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

Contact Information

If you have any questions or comments about this California Alumni Portal Privacy Addendum, the ways in which Foley collects and uses your information described in this California Alumni Portal Privacy Addendum or in the Alumni Portal 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 Alumni Portal Privacy Notice.

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