Effective Date: February 17, 2020
This Privacy Statement applies to the Greenberg Traurig Alumni Network site (www.alumni.gtlaw.com) (“Alumni Site” or “Site”), communications, surveys and other Alumni Program services ("Services"). If you use the Services, your personal data will be collected and used only in accordance with the terms of this Privacy Statement and applicable data privacy laws.
The purpose of the Alumni Program is to maintain a long-term relationship with you and other former employees after your departure from our company. There are many reasons we have an interest in a long-term relationship with you. For example, we may want to rehire you or receive candidate referrals from you, or to do business with you and/or your future employer(s). Also, we hope our Alumni Program and this Site will be beneficial to you by making it easy to stay connected with Greenberg Traurig and your former colleagues.
Use of this Site is subject to our Terms and Conditions and this Privacy Statement. Please read the Terms and Conditions and this Privacy Statement carefully before you use our Services. By using our Services, you accept the Terms and Conditions and accept our privacy practices described in this Privacy Statement. If you do not feel comfortable with any part of this Privacy Statement or our Terms and Conditions, you must not use or access our Services.
This Privacy Statement may change from time to time so please check back periodically. If we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may delete your account (email email@example.com with the message “Please delete my account”). Your continued use of our Services after we publish or send a notice about our changes to this Privacy Statement means that you are consenting to the updated Privacy Statement.
The Alumni Site is a private Site available only to alumni and attorneys of Greenberg Traurig. Please do not give out your username or password to anyone. If you know of an alumnus looking to get access, please ask them to register at the Site. In addition, please respect the privacy of other alumni members and do not give out personal data obtained from the Site to anyone.
1. What personal data do we collect?
Personal data you voluntarily provide us
The Alumni Site collects personal data when you directly give it to us, such as, when you register. During registration and profile set-up, we require that you provide your name and email address. Your user profile offers you the opportunity to provide a wide range of additional information, including photo, postal address, current occupation, industry, education, skills, and personal and business interests. By providing complete and accurate information in your profile, you enable us to customize your experience and help you get the most from our Services. However, please supply only information that is relevant for the stated purposes of this Site.
We also collect personal data in the following situations:
- correspondence between you and the Alumni Site;
- information you post on the Alumni Site, such as, resumes, job applications, event RSVPs, comments on news articles; and
- responses to online surveys or forms that we use for Greenberg Traurig feedback, research and product improvement.
Please keep in mind that whenever you voluntarily disclose personal data online - in the optional fields in your profile, through email, or in areas of the Site - that information could be accessible to the rest of the members of the Greenberg Traurig Alumni Network and may be made public. Please do not post or add personal data to your profile or elsewhere on the Site that you would not want to be publicly available.
Information we collect automatically
When you use the Alumni Site, we collect information about your visit and usage of the Alumni Program services. Some of this information is collected using a third-party tool, provided by Google Analytics service. That information may include your IP address, your operating system, your browser ID, and other information about how you interacted with the Site. We use this information to improve our services and the user experience as well as network management and security.
Personal data provided by Greenberg Traurig
Greenberg Traurig may share your personal data with Conenza during the registration process to verify that you are a Greenberg Traurig alumnus/a. This information may include, but is not limited to, your name, email address, last Greenberg Traurig home office, position and level.
What about sensitive personal data?
We do not generally collect sensitive personal data through this Site. The term "sensitive personal data" refers to the various categories of personal data identified by European and other data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent. These categories may include personal identity numbers; racial or ethnic origin; political opinions; religious, philosophical or other similar beliefs; membership in a trade union or profession or trade association; physical or mental health; biometric or genetic data; sexual orientation; or criminal record (including information about suspected criminal activities).
In the limited cases where we may collect sensitive data, we will do this in accordance with local data privacy law requirements. If you choose to provide us or members of the Alumni Site with unsolicited sensitive personal data, by providing us with such data you consent to our using the data, subject to applicable law as described in this Privacy Statement and in compliance with jurisdiction-specific privacy and data protection regulations therein.
2. Cookies and other tracking technologies
Cookies are useful because they allow a site to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.com. For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies. Generally, we use first-party and third-party cookies for the following purposes:
- to make our Services function properly;
- to provide a secure browsing experience during your use of our Services;
- to collect passive information about your use of our Services;
- to measure how you interact with our marketing campaigns;
- to help us improve our Services; and
- to remember your preferences for your convenience.
Types of cookies on our Services
Cookies do a lot of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. A list of all the cookies used on this Site by category is set out below.
- Strictly necessary cookies – These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for cannot be provided.
- Performance or analytic cookies - These cookies collect information about how visitors use a site; for instance, which pages visitors go to most often, and if they get error messages from webpages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a site works. Performance cookies used by the Site include Google analytics tracking cookies, used to track analytics of site use, including pages viewed and whether the individual is a new or repeat visitor.
- Functional cookies - These cookies allow a site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a site may be able to provide you with local information or news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of the Site’s pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. We may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile. In some cases, we pass this information on to others within Greenberg Traurig for marketing or analysis purposes. In most cases, we will not be able to track individuals by name. Only if a user is a registered user, will we associate the cookie information with a named individual. These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the internet outside our Site. Functionality cookies used by the Site include Conenza tracking cookies to authenticate the user by log-in details and remember language selection, and social login cookies to remember when someone has previously used social log-in.
We use Google Analytics to collect information about the effectiveness of our Services. Google Analytics uses "cookies", text files stored on your computer, to learn about how people use our Site. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service: https://marketingplatform.google.com/about/analytics/terms/us/ and the Google Privacy: https://policies.google.com/privacy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics at https://policies.google.com/technologies/partner-sites. You can prevent your information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
What if I don’t want cookies?
If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. For more information on managing cookies see www.allaboutcookies.org/manage-cookies/. Please bear in mind that deleting and blocking cookies will have an impact on your user experience as parts of the Site may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon you visit our Site, even if you have previously deleted our cookies. Turning off cookies will also prevent any web beacons from tracking your user activity on our Site. The web beacon will still account for an anonymous visit, but your unique information will not be recorded.
Do Not Track
Some browsers have incorporated Do Not Track (“DNT”) preferences, but our Services do not respond to DNT signals at this time because we do not track your activities across the internet and off of our Services.
3. How do we use your personal data?
The Alumni Program will use your personal data for the following purposes:
- To provide our users with a customized experience on our Site, including personalization services, such as, suggested contacts, news, events and interactive communications.
- To enable other users to search for and locate you via the directory.
- For internal use. We will use your personal data to research and analyze our users' demographics, interests and behavior in an aggregated form to better understand and serve our users and improve our Site and its offerings.
- To contact you periodically with communications about events, publications or employment opportunities with Greenberg Traurig, affiliates or partners, which we feel might interest you, unless you ask not to be contacted. You will have an opportunity to opt out of receiving further messages.
- To get your feedback and viewpoints through polls and surveys conducted by us and others. You are not obligated to respond to polls and surveys and can choose the information you provide.
- To share with other internal Greenberg Traurig systems for a variety of reasons including to contact you with professionally relevant information.
- To provide you our services. We will use your personal data to provide information or perform Services that you request.
- To enforce compliance with our terms and policies. We process your personal data to: investigate, prevent or mitigate violations of our policies, terms or agreements; and enforce our agreements with third parties and service providers.
- To ensure the security of the services. We care about keeping you secure and safe while using our Services.
- To maintain legal and regulatory compliance. Our Services are subject to certain laws and regulations which may require us to process your personal data.
We may also use data for other purposes, which we would always describe to you when we collect the information.
4. Who has access to your personal data?
As a global organization, personal data that Greenberg Traurig collects may be transferred internationally within Greenberg Traurig’s worldwide organization, in accordance with the Privacy Statement, Terms and Conditions or as otherwise communicated from time to time and in relation to the Greenberg Traurig Alumni Program.
We will share your personal data in the following situations.
- With other users of the Site through the Directory search function and your Profile. You have control over this access through the privacy settings in your Profile. Click on the edit icon or button in any section of the Profile to find the privacy settings. These have been set to “Members” by default, meaning all members of the Site can see this information. You can select to make information in your profile visible to only you, just your contacts, all members of the Alumni Site, or all parties including third-party job posters. Regardless of your privacy setting, Greenberg Traurig and Conenza will have access to your profile information.
- With our service providers, including Conenza, Inc. who provides the corporate alumni software platform and services and its contractors. These service providers may engage additional companies to be able to support us. These companies may use your personal data only to assist the service providers in communicating with you about the Services and to help service providers in assisting us with operating the Services. Such companies do not have any independent right to use or disclose your personal data except as we request.
- With business partners or sponsors where this is necessary for the purposes related to the Alumni Program, in which case this will be specifically described to you prior to data collection or prior to transferring the data, and you can choose not to allow the transfer by not using that particular service.
- With advisors, including attorneys and accountants, to help us with legal, accounting and security requirements.
- When required to comply with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To a third-party acquirer if Greenberg Traurig or Conenza sells or liquidates all or any part of its business or assets. In that event, any acquirer will be subject to our obligations under this Privacy Statement and you will have the same rights with respect to your personal data.
We do not share your personal data with third-parties for marketing purposes, and we do not rent or sell your personal data to others.
5. How do we safeguard your personal data?
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
Your user account information is password-protected so that only you, Conenza and Greenberg Traurig have access to your personal data. Do not divulge your password to anyone. Also remember to sign out of your account and close your browser window when you have finished using the Site, particularly if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.
Our Site may, from time to time, contain links to other sites. If you follow a link to any of these sites, please note that these sites have their own privacy statements and that we do not accept any responsibility or liability for these statements or sites. Please check these privacy statements before you submit any personal data to these sites.
Our Services are not directed to children under the age of 18. We do not knowingly collect personal data from any child under the age of 18. If we become aware that a child under 18 has provided us with personal data, we will take steps to delete such information from our files.
7. What are your rights?
You are entitled to know what personal data we process and store about you and to have access to that information. You can access, edit or correct the information in your profile at any time. Log in to the Alumni Site and click on Profile. If you have forgotten your password, click on the Forgot Password link and we will send an email to your primary email address.
You can choose not to receive any communications from us about events or publications we feel might be of interest to you. Finally, you can ask us to deactivate, delete or transfer your personal data, but then you may not be able to access any members-only areas of the Site. If you choose to delete or transfer your account, we will delete any residual information after 60 days, unless otherwise required by law.
We will retain your personal data only as long as you have a user account on the Alumni Site. If you decide to delete your user account, we will retain your data for 60 days before permanently deleting the data, unless legally required to retain the information for a longer period of time.
You can exercise any of these rights or ask any questions by contacting us at:
Greenberg Traurig Alumni Network
1411 4th Avenue, Suite 1000
Seattle, WA 98101
For individuals located in the European Economic Area (“EEA”), Switzerland or the United Kingdom at the time they access our Services, please see Special Notice section below.
8. California Privacy Rights
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the personal information categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your personal information, where we obtain the personal information, and the third parties that we share your personal information.
Personal information categories we collect
We generally collect the following categories of personal information (“personal information“) about your when you use our Services:
- identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
- protected classifications such as gender;
- commercial information such as records of products or services purchased, obtained, or considered by you;
- Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
- your geolocation, to the extent you have configured your device to permit us to collect such information;
- audio recordings of your voice to the extent you call us, as permitted under applicable law;
- education-related information;
- professional or employment-related information; and
- inferences about your preferences, characteristics, behavior and attitudes.
We generally do not collect biometric information. For more information about the personal information we collect and how we collect it, please refer to sections 1 and 2 above.
Purposes for processing personal information under the CCPA
We collect your personal information for the business purposes described in sections 2 and 3. The CCPA defines a “business purpose” as the use of personal information for the business’s operational purposes, or other notified purposes, provided the use of personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected.
The following activities are considered “business purposes” under the CCPA: auditing related to a current interaction with the consumer and concurrent transactions, and auditing compliance with laws and other standards; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, verifying customer information; repairing errors that impair existing intended functionality; Internal research for technological development; verifying or maintaining the quality or safety of, and improving, upgrading, or enhancing, a service or device that is owned, manufactured by, manufactured for, or controlled by the company.
Third party sharing
The categories of third parties with whom we may share your personal information are listed in section 4 above.
If you are a California resident, you have rights in relation to your personal information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of our network systems. To assert your right to know or your right to delete your personal information, please contact us at firstname.lastname@example.org. To verify your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
- Right against discrimination - You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
- Right to know - You have the right to request in writing: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request.
- Right to delete - You have the right to request us delete any personal information we have collected from you or maintain about you, subject to certain exceptions.
- Right to opt-out of selling -The CCPA broadly defines “personal information” and “selling” such that sharing identifiers linked to you for a benefit may be considered a sale. You have the right to opt-out of having your personal information sold. We do not sell your personal information.
9. International transfers of personal data
When you access or use our Services, we may transfer your personal data to countries in the world where Greenberg Traurig conducts business. Such countries may be located outside of the country or jurisdiction where you are located and may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. In such countries, Greenberg Traurig will still handle your personal data in the manner describe herein. If you do not want your data transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.
Individuals located in the EEA, Switzerland or the United Kingdom at the time they access our Services, please see next section which addresses the mechanisms used to transfer your personal data
10. Special notice to individuals in the European Economic Area, the United Kingdom and Switzerland
This section only applies to individuals that access or use our Service while located in the EEA, the United Kingdom or Switzerland (collectively, the “Designated Countries”). We may ask you to identify which country you are located in when you use some of the Services or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Privacy Statement, the terms in this section shall apply to users in the Designated Countries.
Our relationship to you
For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Greenberg Traurig serves as the controller of the personal data you provide us. A “controller” is an entity that determines the purposes for which and the manner in which any personal data is processed.
Legal bases for processing your personal data
Article 6(1) of the GDPR describes when processing can be done lawfully. When we process your personal data for a specified purpose, we shall apply one of the Article 6 legal bases. Thus, our processing will be based on your consent, for the performance of a contract between you and Greenberg Traurig or for taking any pre-contractual steps upon your request, to comply with a legal obligation, or when it is necessary for the purposes of Greenberg Traurig’s or another party’s legitimate interests.
We take reasonable steps to ensure that your personal data is accurate, complete, and up to date. You have the right to access, correct, or delete the personal data that we collect. You are also entitled to restrict or object, at any time, to the further processing of your personal data. You have the right to receive your personal data in a structured and standard format and, where technically and legally feasible, the right to have your personal data transmitted directly to another controller. If you would like to exercise your rights under applicable law, please contact us at email@example.com, indicating “EEA Individual Rights Request” in the subject line of the email.
If we share your personal data in accordance with this Privacy Statement, this may include the transfer of your personal data to countries outside the Designated Countries. Greenberg Traurig, P.A. and Greenberg Traurig LLP participates in and has certified their compliance with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries, the United Kingdom, and Switzerland transferred to the United States pursuant to Privacy Shield. See EU-US Privacy Shield and Swiss-US Privacy Shield Policy (“Shield Policy”). If there is any conflict between the policies in this Privacy Statement and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern in relation to Greenberg Traurig, P.A. and Greenberg Traurig LLP. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
Our accountability for personal data we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event(s) giving rise to the damage.
Right to lodge complaint
If you believe we have infringed or violated your privacy rights, please contact us at firstname.lastname@example.org so that we may resolve your dispute directly. If you are a data subject with an unresolved complaint or dispute arising under the requirements of the Privacy Shield Framework, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism. Our independent dispute resolution mechanism is the International Centre for Dispute Resolution (“ICDR”), operated by the American Arbitration Association (“AAA”). For more information and to file a complaint, you may contact the International Centre for Dispute Resolution by phone at +1.212.484.4181, or by visiting this website http://info.adr.org/safeharbor. See Shield Policy for more information. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence or place of alleged infringement.
11. How to contact us
You can contact us via email at email@example.com. If you prefer to contact us by postal mail, please contact us at: Greenberg Traurig Alumni Network, c/o Conenza, 1411 4th Avenue, Suite 1000, Seattle, WA 98101.