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PRIVACY

Last Updated: November 1, 2023



Hogan Lovells International LLP, Hogan Lovells US LLP, and our affiliated
businesses (collectively, “Hogan Lovells,” “we,” “our”) are committed to being
responsible custodians of the personal information that we collect in the course
of operating our business as a global provider of legal and other services.

This Privacy Notice (“Notice”) describes how we collect, use, share, or
otherwise process personal information as a data controller in the course of
operating our business, particularly in association with our marketing and
business development practices and the operation of our main website
(www.hoganlovells.com), and our other digital properties that link to this
Notice, including our websites, mobile applications, and digital communications
(collectively, “Digital Services”).

While we may also process personal information during our legal representation
of a client, such processing is performed on behalf of and at the direction of
our client, subject to our client agreements and professional responsibilities,
and is not covered by this Notice.

“Personal information” as used in this Notice means information that identifies,
relates to, describes, or can reasonably be linked, directly or indirectly, to a
specific natural person. It does not include information that is considered
anonymous, de-identified, or aggregated by applicable law.

Some Hogan Lovells offices have notices that differ from this one. Please click
here to view the privacy policy for our Australian offices. Please click here to
view the PAIA manual for our South African offices.

This Notice covers the following topics:



> 1. The Types of Information We Collect
> 
> 2. How We Use the Information We Collect
> 
> 3. How We May Share the Information We Collect
> 
> 4. Grounds for Processing Your Information
> 
> 5. Third-Party Services and Content
> 
> 6. Protection and Storage of the Information We Collect
> 
> 7. Your Choices and Rights
> 
> 8. How to Contact Us
> 
> 9. Changes to This Privacy Policy




1. The Types of Information We Collect

The types of personal information we collect about you depend on your
interactions with us and are described below.

Information You Provide to Us

We collect personal information that you provide to us. For example, we may
collect personal information when you contact us, request that we send you
newsletters, alerts, or other materials, register for a webinar or event, fill
out a form, respond to a survey, comment on a blog, or otherwise communicate
with us.

Depending on the context of your interactions with us, the categories of
personal information we may collect from you include:

 * Unique Identifiers that we can use to identify you as a unique individual,
   such as your name, telephone number, postal or e-mail address, bar license
   number, social media identifiers, signature, and government issued
   identification numbers (such as your social security number or passport
   number). If you have registered with a Digital Service, we may also collect
   your account username and password.

 * Demographic Information, which may include sensitive personal information or
   information about protected classifications, such as your age, gender, race,
   sexual orientation, marital status, or veteran status.

 * Professional and Educational Information related to your occupation, such as
   your current or previous employers, your job title, or other information
   about the organization with which you are affiliated. You might also provide
   information about your professional qualifications or your education, such as
   your bar information, degrees, fields of study, the institutions you’ve
   attended, languages, professional memberships, qualifications, and
   certifications.

 * Health Information, such as accessibility requirements and dietary
   restrictions.

 * Geolocation Information, such as your city, state or province, and country.
   When you access the Digital Services, we may collect precise geolocation
   information if you permit the Digital Services to access such information so
   that we may provide you with content based on your location and your
   proximity to our offices.

 * Audio and Visual Information, such as your voice and likeness as captured in
   photographs, video, or audio recordings if you attend our events, visit our
   offices, or leave us a voicemail.

 * User Content, such as comments or other material you post to our social media
   pages, blogs, or other forums on our Digital Services.

 * Preferences, such as your stated interests, how frequently you wish to
   receive our newsletters, or other communications.

 * Any other information you choose to provide.



You generally can use our Digital Services without providing us with personal
information, though we may still collect personal information automatically as
described in the next section.

Information We May Collect Automatically or Generate

We may automatically collect and generate information from and about you when
you interact with us or our Digital Services, which may include the following
categories of personal information:

 * Unique Identifiers: We might automatically collect information that uniquely
   identifies you or the device through which you interact with our Digital
   Services, such as your name, e-mail address, username, social media
   identifiers, IP address, and device and mobile advertising identifiers.

 * Device Information: We might automatically collect information pertaining to
   the device through which you interact with our Digital Services, such as the
   type of device used to interact with the Digital Services, that device’s
   operating system and version, your browser type.

 * Interaction Information: We might automatically collect information about
   your interaction with our Digital Services, such as the content you view and
   features you access on our Digital Services, the pages you view immediately
   before and after you access our Digital Services, whether and how you
   interact with content available on our Digital Services, and the search terms
   you enter on our Digital Services. We might also collect information about
   the events and materials in which you have indicated interest or for which
   you have registered or requested.

 * Geolocation Information: We might automatically collect information regarding
   your location, such as your ZIP code, city, state or province, country, or
   general geographic location as derived from your device data (such as your IP
   address).

 * Inferences drawn from your interactions with our Digital Services, the events
   you choose to attend, or any of the other personal information available to
   us.



We and our service providers or third parties engaged on our behalf may use
cookies and similar tracking technologies (collectively, “Cookies”) to collect
information from and store information on your device when you use, access, or
otherwise interact with our Digital Services. For information about how we use
Cookies and the choices you may have, please see our Cookies Policy. We do not
currently respond to “Do Not Track” signals.

Information We Collect From Other Sources

We may obtain personal information from other sources, such as our clients,
employees, or business partners, or from business contact databases and
enrichment services. We may also receive information about you from social media
platforms, such as when you interact with us on those platforms or access our
social media content. We may collect information about you from publicly
available sources, such as public social media profiles, publications, and other
websites or materials available through search engines.

We may collect the following categories of information from these other sources:

 * Unique Identifiers, such as name, telephone number, postal or e-mail address,
   social media identifiers, and device and mobile advertising identifiers.

 * Professional and Educational Information about your occupation and
   professional activities, such as professional licenses held, employers,
   business contact information, or information about your education, such as
   your degrees, fields of study, institutions attended, languages, professional
   memberships, qualifications, and certifications.

 * User Content you post or make available online, such as your social media
   posts or publications.



2. How We Use The Information We Collect

We may use the information we collect for the various purposes, including:

 * To respond to your inquiries or communications.
 * To provide you with legal and other services.
 * To operate, troubleshoot, and improve the Digital Services.
 * To send you newsletters, legal updates, marketing communications, and other
   information or materials that may interest you.
 * To expand and maintain our list of contacts.
 * To manage your online account(s) with our Digital Services and send you
   technical notices, updates, security alerts, and other administrative
   messages.
 * To understand how people use our services, including by generating and
   analyzing statistics.
 * For Hogan Lovells’ business purposes, including internal administration, data
   analysis, billing, and detecting, preventing, and responding to actual or
   potential fraud, illegal activities, or intellectual property infringement.
 * To advertise, provide, and assess the effectiveness of our events,
   promotional campaigns, publications, and services.
 * As we believe reasonably necessary or appropriate to comply with our legal
   obligations, to respond to legal process or requests for information issued
   by government authorities or other third parties, or to protect your, our, or
   others’ rights.



We may use anonymous, de-identified, or aggregate information that does not
reasonably identify you for any purpose, as permitted by applicable law.

3. How We May Share the Information We Collect

Hogan Lovells does not sell your personal information. We also do not share
personal information that reasonably identifies you with unaffiliated entities
for their independent use except when we have your permission, are doing so at
your direction, as needed to comply with our legal obligations, as permitted by
applicable law, or as otherwise described in this Notice.

We may also disclose the categories of information we collect to the following
categories of recipients in furtherance of the purposes described above:

 * Our affiliates: We may share information with our Hogan Lovells offices and
   business entities located in jurisdictions around the world for any of the
   purposes listed above.

 * Our service providers: We may share information with third parties that
   perform services on our behalf, such as web-hosting companies, mailing
   vendors, analytics providers, event hosting services, and information
   technology providers.

 * Law enforcement, government authorities, or third parties with legal rights:
   We may share information as may be permitted or required by the laws of any
   jurisdiction that may apply to us, as provided for under contract, or as we
   deem reasonably necessary to provide legal services. In these circumstances,
   we strive to take reasonable efforts to notify you before we disclose
   information that may reasonably identify you or your organization, unless
   prior notice is prohibited by applicable law or is not possible or reasonable
   in the circumstances.

 * Parties in connection with a business transaction: We may share information
   with service providers, advisors, potential transactional partners, or other
   third parties in connection with the consideration, negotiation, or
   completion of a transaction in which we are acquired by or merged with
   another company or we sell, liquidate, or transfer all or a portion of our
   assets, as well as any bankruptcy or corporate reorganization.

 * Others with your consent or at your direction, including if we notify you
   that your information may be shared and you provide such information or if
   you use Hogan Lovells to interact with a third party. For example, we may
   share your name and bar number with your employer or state bar association in
   connection with an application for CLE credit, or we may share your name and
   contact information with a business partner who co-sponsors an event you
   attend or publication you sign up for or with a social media service if you
   share or like our content.



We may share anonymous, de-identified, or aggregate information that cannot
reasonably identify you with others for any purpose, as permitted by applicable
law. Please note that any personal information that you post to a profile, blog,
comment section, or forum on our Digital Services or social media pages may be
available to other users of those forums or, in some cases, made publicly
available.

4. Grounds for Processing Your Information

Certain jurisdictions require businesses such as Hogan Lovells to have legal
grounds for processing personal information. Where applicable law requires us to
justify our processing activities, we rely on the following legal grounds:

 * Performance of a contract: We may need to collect and use your personal
   information to enter into a contract you or to perform a contract that you
   have with us. For example, when you use our Digital Services we will use your
   personal information to respond to your requests and provide you with such
   services.

 * Consent: Where required to obtain your consent, we will do so. For example,
   certain jurisdictions require us to obtain your consent to process precise
   location information. To withdraw your consent to such use, you can contact
   us via our Contact Us page, or, with respect to precise location information,
   you may be able to disable the sharing of location information in your
   browser or mobile application settings. Where required by applicable laws, we
   will rely on your consent for direct marketing and to collect information
   from your device or computer.

 * Legitimate interests: We may use your personal information for our legitimate
   interests to improve our products and services, as well as the content on our
   Digital Services. Consistent with our legitimate interests and any choices
   that we offer or consents that may be required under applicable laws, we may
   use technical information and personal information for our marketing
   purposes.

 * Legal obligation: We may process personal information as necessary to comply
   with our legal obligations.



5. Third-Party Services and Content

Our Digital Services may include integrated content or links to content provided
by third parties (such as video materials). This Privacy Notice does not address
the privacy, security, or other practices of the third parties that provide such
content.

Consistent with applicable law, we engage third parties that support the
operation of our Digital Services, such as analytics providers. These third
parties may track your online activities over time and across different websites
and applications. Please see our Cookies Policy for more information about such
third party providers and your choices.

6. Protection and Storage of the Information We Collect

We deploy commercially reasonable administrative, technical, and physical
safeguards designed to comply with applicable legal requirements and safeguard
the information that we collect. This includes, when required or appropriate and
feasible, obtaining written assurances from third parties that may access your
personal information that they will protect such information with safeguards
designed to provide a level of protection equivalent to those adopted by Hogan
Lovells.

However, no information system can be 100% secure. We cannot guarantee the
absolute security of your information. Moreover, we are not responsible for the
security of information you transmit to us over networks that we do not control,
including the Internet and wireless networks.

The Digital Services are controlled and operated by Hogan Lovells from the
United States. We may store the information we collect in the United States or
in other countries where we or our service providers have facilities. We may
transfer information to countries outside of your country of residence,
including the United States, which may have data protection laws and regulations
that differ from those in your country.

Any transfers of information originating from within the European Economic Area,
the United Kingdom, and Switzerland to countries outside the EEA, UK, or
Switzerland will normally be made on the basis of the model clauses approved by
the European Commission for transfers from EU controllers to non-EU controllers,
which may be found at the Commission's website at https://ec.europa.eu. We
retain the information we collect no longer than as reasonably necessary to
fulfill the purposes for which we collect the information and to comply with our
legal obligations.

7. Your Choices and Rights

Marketing Communications. If you no longer wish to receive marketing
communications from us, you can let us know by contacting us using the
information available in the How to Contact Us section below. Our digital
marketing communications may provide unsubscribe or opt-out mechanisms that
allow you to modify your communications preferences. Please note that if you
opt-out of marketing communications, we may still contact you with
non-promotional communications, such as those about ongoing business relations
or administrative messages.

Cookies. For information about the choices you may have in regard to our use of
Cookies, please see our Cookies Policy.

Geolocation Data. If you have previously consented to sharing precise
geolocation information with our Digital Services, you can choose to stop the
collection of this information at any time by changing the preferences on your
browser or mobile device settings.

Push Notifications/Alerts. If you have permitted one of our mobile applications
to send you push notifications or alerts, you can deactivate these messages at
any time in the notification settings on your mobile device.

Privacy Rights. As an international law firm, Hogan Lovells operates in
jurisdictions that impose varying obligations and that grant individuals
differing levels of protection, particularly with respect to personal
information. Depending on applicable law, you may have certain rights with
respect to your personal information, including, for example, the rights to:

 * Request access to certain personal information of yours that we process.
 * Update or correct your personal information if you believe it is incomplete
   or inaccurate.
 * Erase or delete your personal information, subject to certain exceptions
   under local law.
 * Object to our processing of your personal information or otherwise restrict
   our processing activities.
 * Restrict certain transfers of your personal information to third parties.
 * Withdraw your consent to processing, where we base our processing of your
   personal information on consent.
 * Not be denied goods or services for exercising your rights under applicable
   law.
 * Complain to your local supervisory authority.



You can exercise your rights (if applicable) by submitting a request through our
Contact Us page or emailing our Data Protection Officer at dpo@hoganlovells.com.
California residents can also submit requests toll-free by calling +1 (866)
720-0002 and indicating they wish to submit a California Consumer Privacy Act
rights request to Hogan Lovells.

8. How to Contact Us

We welcome your inquiries and comments. But please note that if you are not a
client, we may not be able to treat the information you send us as confidential
or privileged. If you wish to contact us regarding legal or other services,
please contact an attorney in one of our offices near you. You can find a list
of our offices and our attorneys on our main website (www.hoganlovells.com).

If you would like to contact us with questions about our privacy or data
protection practices, please contact our data protection officer at
dpo@hoganlovells.com or send us an email via our Contact Us page.

9. Changes to this Privacy Notice

We may update this Notice periodically, and will revise the date at the top of
this Notice to reflect the date when such update occurred. If we make any
material changes in the way we collect, use, and/or share the personal
information that you have provided, we will endeavor to provide you with notice
before such changes take effect, such as by posting prominent notice on the
Hogan Lovells website.



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Advertising cookies may also be set through our site by other companies. They
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relevant adverts on other sites. They do not store directly personal
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advertising. Details of these companies can be found in our Cookie policy.



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We also deploy a survey tool which is designed to collect information on
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other details are collected from you (with your consent) if you respond to an
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