Privacy Policy

This Privacy Policy applies to personal data collected online by Vorys, Sater, Seymour and Pease LLP, its subsidiaries, or affiliates (collectively, “Vorys” or “we” or “us” or “our”) through its websites, microsites, or mobile sites that expressly adopt, display or link to this Privacy Policy (collectively, the “Website”). “Social Media Pages” are the official social media pages we operate on Facebook, Twitter, LinkedIn, and other social media platforms.  If you have any questions about these definitions or anything else in this Privacy Policy, please contact us.

This Privacy Policy answers the following questions:

  1. What information does Vorys collect about you on our Website?
  2. How do we collect your information?
  3. How do we use the information we collect about you?
  4. How long do we keep your information?
  5. How does Vorys share information with Service Providers and Third Parties and for what purposes?
  6. What are my privacy choices?
  7. How does Vorys address children’s privacy?
  8. How does Vorys secure personal information on our Website?
  9. How does our Website interact with third-party websites and content?
  10. Where is personal information stored and processed?
  11. What other terms govern my use of the Website?
  12. Will this Privacy Policy change?
  13. Your U.S. State Privacy Rights
  14. Your International Privacy Rights
  15. How may I contact Vorys?

1. What information does Vorys collect about you on our Website?

We collect different types of information about our Website visitors, including:

2. How do we collect your information?

We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:

3. How do we use the information we collect about you?

We only use your information for legal and legitimate purposes, such as:

4. How long do we keep your information?

We will retain your information for as long as is necessary to fulfil the purpose for which your information was collected and in accordance with our internal retention procedures, or as otherwise necessary to satisfy our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your information for research or statistical purposes in which case we may use such anonymized information indefinitely.

5. How does Vorys share information with Service Providers and Third Parties and for what purposes?

Vorys may share personal information with third parties for certain purposes. For example, we may share personal information with:

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, the EEA, UK, or Switzerland you can learn more about your privacy rights below.

6. What are my privacy choices?

You can control the information we collect and use in the following ways:

7. How does Vorys address children’s privacy?

Our Website and Social Media Pages are not intended for children under 16. No one under 16 should share any personal information with us. We do not knowingly collect any personal information from children under 16. To request deletion of personal information relating to a child under 16, please contact us.

8. How does Vorys secure personal information on our Website?

We employ physical, technical, and administrative procedures to safeguard the personal information we collect online.  While we use these security measures on our Website, you should be aware that 100% security is not always possible.

9. How does our Website interact with third-party websites and content?

For your convenience, we may enable you to navigate to third-party sites through links on our Website.  We do not endorse these third-party sites, do not have any affiliation with these third-party sites, and we do not control and are not responsible for their Internet and web practices.  Whether the third-party content appears within our Website environment (like a map frame), or you leave our Website for another website to view it, the terms, conditions, and privacy policies of those other websites govern your online experience.  Please review their separate terms of service and privacy policies if you have any questions about their practices.

10. Where is personal information stored and processed?

We are an international law firm that provides cross-jurisdictional legal advice and related services to our clients. The global nature of our business means that your information may be transferred outside the jurisdiction in which you provide it, including, potentially, to countries that do not require organizations by law to look after your personal information in the way in which you have come to expect in your own country. The European Commission has not made an adequacy determination with respect to data transfers to the United States, and if you live in the EEA, the UK, or Switzerland, United States privacy laws may not provide you the same rights you may have in your own country. Personal data provided to our UK affiliate is transferred to the United States under the terms of an International Data Transfer Agreement on the form approved by the UK Information Commissioner’s Office. You may obtain a copy of the IDTA by contacting us at privacy@vorys.com.

Where we transfer your personal information across national boundaries, we will protect your information by ensuring that those transfers are made in compliance with all relevant data protection laws.

11. What other terms govern my use of the Website?

Your use of the Website is also governed by the Terms of Use and Disclaimer.

12. Will this Privacy Policy change?

We may make changes to this Privacy Policy at any time to take into account new or changing circumstances, so please review it periodically.  If we make a material change to our information collection, use, or disclosure practices specified in this Privacy Policy, it will be applied only to information collected on a going forward basis.  By visiting the Website or submitting information, you agree to the terms of this Privacy Policy and consent to receive notice of any material changes to this Privacy Policy or material changes in our collection, use, or disclosure of your personal information as specified in this Privacy Policy, by postings on the Website or by email, as determined by Vorys.  We will update the effective date at the top of the page at the time a change is made.

13. Your U.S. State Privacy Rights

Residents of California, Virginia, Connecticut, Colorado, and Utah have certain rights concerning the processing and use of their Personal Data.  The rights described herein are subject to exemptions under applicable law.  For purposes of this section, the term “Personal Data” includes both “Personal Information” and “Personal Data” as defined by applicable law.

If your Personal Data is subject to a privacy law in your state, you may have certain privacy rights with regard to that information.  You may have the right to:

Under certain state laws, you may also have the right not to receive discriminatory treatment for the exercise of any of these privacy rights.  We will not discriminate against you because you have exercised any of your rights.

Certain state laws may also provide you the right to appeal our decisions regarding your rights requests if we do not respond to your requests or do not take action regarding your requests. Additionally, if you are a resident of the state of California, you may have a right to pursue legal action for improper handling of your Personal Data.

How to Submit a Request

If you wish to exercise the rights listed above, and are a resident of a state that provides such privacy rights, you may submit a request by emailing privacy@vorys.com, by calling us toll-free at 1-833-525-2097, or by using this form. We will provide your Personal Data to you in writing in a readily usable format.  If you choose to submit your request via email, you must include “Privacy Rights Request” in the subject line and clearly provide us with the following information: what type of request you are making, your full name, email address, and valid physical address.  You may only make one request per email. 

We are required to provide you with access to your Personal Data or delete your Personal Data only in response to verifiable consumer requests. We will compare the information you provide to us in your request to any information we may have in our possession in order to verify your request. You may be asked to provide us with information such as your home address, email address, and telephone number. We may also contact you to request additional information in relation to your request. Please promptly respond to any follow-up inquiries so that we may verify your identity. If you request that we provide you with specific pieces of information about you, or that we delete sensitive Personal Data, we may apply heightened verification standards than what we would apply to other types of requests. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Data is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used for verification purposes only.

Authorized Agent

Please note that you may authorize an agent to exercise any of these rights on your behalf by contacting us toll-free at 1-833-525-2097 or by submitting the request via this form. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling any access or deletion requests. We may require more information to ensure proper verification of you and your agent’s identity and authorization.

Categories of Personal Data Disclosed for a Business Purpose

We share personal data about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the services you seek from us.  For more information about the business purposes for which we disclose Personal Data, see How do we use the information we collect about you? and see What information does Vorys collect about you on our Website? for what types of information may be shared.

“Do Not Sell” Rights; Sharing for Cross-Context Behavioral Advertising, Profiling, or Targeted Advertising

We may disclose your Personal Data for the following purposes, which are not a sale: (i) for reasons mentioned above; (ii) if you direct us to share Personal Data; (iii) to comply with your requests under applicable law; and (iv) as otherwise required or permitted by applicable law.

We do not sell Personal Data or share Personal Data about you for purposes of cross-context behavioral advertising, profiling, or targeted advertising.

Deletion Rights

You may request that we delete your Personal Data that we have collected directly from you.  Under applicable law, we may decline to delete your Personal Data under certain circumstances, for example, if we need the Personal Data to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for internal business purposes (including maintaining business records), to comply with law, or to exercise or defend legal claims.  Note also that we are not required to delete your Personal Data that we did not collect directly from you.  We require a reasonable or high degree of certainty that the requester is the consumer for which a deletion request is applicable, depending on the sensitivity of the Personal Data.

Additional California Privacy Rights

We do not share Personal Data as defined by California Civil Code Section 1798.83 (“Shine the Light Law”) with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by contacting us through this form or sending a letter to Vorys, Sater, Seymour and Pease LLP at 52 E Gay St, Columbus, OH 43215, (Attention: Privacy Inquiry).  Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  Please note that we are only required to respond to one request per individual each year, and we are not required to respond to requests made by means other than through this form or mail address.

California Consumer Privacy Rights Requests from January 1, 2021 – December 31, 2021

Type of Request

Total Requests Received

Requests Denied

Requests Complied With

Average Days to Respond

Request to Access Data

0

N/A

N/A

N/A

Request to Delete Data

0

N/A

N/A

N/A

Request to Opt-Out of “Sale”

0

N/A

N/A

N/A


Sensitive Data of Virginia, Colorado, or Connecticut Residents

If you are a resident of Virginia, Colorado, or Connecticut, we will not process your Sensitive Data (as that term is defined under the Virginia Consumer Data Protection Act; the Colorado Privacy Act; and Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring) without your prior consent.

14. Your International Privacy Rights

We may transfer your Personal Data (as that term is defined by applicable law) to organizations located in countries other than the one in which the Personal Data was collected.  If you are located in the EEA, the United Kingdom, or Switzerland, you may have certain rights and protections under applicable laws regarding the processing of your Personal Data.  Each of these laws generally affords data subjects the right to:

We do not use profiling (where an electronic system uses Personal Data to try and predict something about you) or automated decision making (where an electronic system uses Personal Data to make a decision about you without human intervention).

In addition to the security measures mentioned above, we will ensure that your Personal Data is adequately protected, for example, by using a contract for the transfer which contains specific data protection provisions. Except as otherwise expressly discussed in this Privacy Policy, this policy only addresses our use and disclosure of Personal Data we collect from you. To the extent that you disclose your Personal Data to third parties, including any third party website linked from any of our websites, you are subject to the privacy customs and policies of those third parties.

Our other obligations to you as our client, if applicable, are not addressed by this Privacy Policy. Those obligations are described in our terms of engagement or otherwise arise as a result of applicable law.

How to Submit a Request

If you are located in the EEA, the United Kingdom, or Switzerland and you wish to exercise any of your rights, please submit your request by emailing us at privacy@vorys.com

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

If you would like to make a complaint about how we handle your Personal Data, or make a complaint about a breach of data protection laws, please contact us using the contact information described above. Complaints will be investigated and the outcome of the investigation will be communicated to you after the complaint is made in accordance with applicable law.  You may have a right in some locations to file a complaint with your local data protection authority.

Legal Basis for Processing

We will process your Personal Data only where we have a lawful basis for doing so. These “lawful bases” for processing are set forth in applicable data protection law and, depending on the relevant circumstances and jurisdiction, our processing will be on the basis of one or more of the following: (a) the performance of a contract to which you are a party or in order to take steps at your request prior to entering a contract; (b) compliance with our legal obligations; (c) for our legitimate interests (this includes carrying out the business of providing legal services and pursuing our general business interests); (d) the establishment, exercise or defense of legal claims; (e) to carry out tasks in the public interest/reasons of substantial public interest; or (f) to comply with laws relating to anti-money laundering or counter-terrorist financing obligations or the prevention, detection, or prosecution of any crime.

In addition, in some circumstances we may process your information if you have provided your consent for us to do so.  Please note that you have the right to withdraw any such consent by contacting us using the contact details below.

Data Retention

We store Personal Data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Protection Principles

When processing your Personal Data, Vorys adheres to the following principles:

Marketing Notice

We may process additional Personal Data provided by you for marketing purposes, for example in relation to an event, when you let us know what legal areas you are interested in, and when you wish to be contacted by us. We will not use your Personal Data to send you marketing materials if you have requested not to receive them. Your Personal Data may also be collected in our relationship management system when you register online to receive legal updates, or when we otherwise receive your contact details. You will receive a confirmation notice when your details have been added to our relationship management system. You can update or request, however, to have your Personal Data removed from our relationship management at any time by contacting us as provided below. You also will be provided with the option to unsubscribe or opt-out from receiving further marketing communications by following the instructions at the bottom of each communication.

Data Protection Authority

If you have a concern about our processing of Personal Data that we are not able to resolve, you may have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

15. How may I contact Vorys?

If you have any questions, comments, or concerns about this Privacy Policy, please contact us by emailing info@vorys.com. When writing us, please make sure to include your name and mailing address or telephone number so that we can contact you.

You may also contact:

Andrew Laux
52 E. Gay Street
Columbus, Ohio 43215
614.464.5449
adlaux@vorys.com 

Effective Date (last updated): August 2022

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