King & Spalding is committed to keeping the Personal Information you provide accurate and up to date. Please assist us with this commitment by informing us of any changes to your Personal Information. 

You have control regarding our use of your Personal Information for direct marketing. In all countries, you can choose to not receive such communications at any time. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, please follow the unsubscribe link in the relevant communication.  We will note the rights of individuals to unsubscribe from mailings and/or manage their preferences in all our mailings, and requests to unsubscribe may also be made by clicking here.

Jurisdictional Rights
Data protection and privacy laws afford various rights to individuals in certain jurisdictions, including the United States (such as California), the European Economic Area (EEA), the United Kingdom (UK) and other jurisdictions which have adopted similar laws, as well as Australia.  Details of those rights and how you may exercise them are set out below.

Rights in California

CCPA

The California Consumer Privacy Act provides California residents (“you” in the following section) with additional, specific rights regarding their Personal Information.

In particular, King & Spalding’s website collects and has collected the following categories of Personal Information from its data subjects within the last (12) months:  Identifiers, Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), Protected classification characteristics under California or federal law, Commercial information, Biometric information,  Internet or similar network activity, Physical location or movements (Geolocation data), Sensory data, and Professional or employment-related information, Non-public education information (per the Family and Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), Inferences drawn from other Personal Information.

Purposes of Collection and Processing in the table below are drawn from the Purpose of Processing and Legal Basis for Processing table on the Privacy Notice.

In the preceding 12 months, King & Spalding has not sold Personal Information covered by the California Consumer Privacy Act, but it has disclosed Categories A – K (all of the above) of Personal Information to Service Providers as listed above in Who We Share and Disclose Personal Information To for a business purpose.

King & Spalding obtains all the categories of Personal Information listed above from at least one of the following categories of sources:

• Directly from you. For example, from forms you complete, services you purchase, emails you send;
• Indirectly from you. For example, from observing your actions on our Website; or
• From third parties. For example, from recruiting agencies and our clients.

Access to Specific Information and Data Portability Rights

You have the right to request that King & Spalding disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable request, which may require collection of additional information from you, we will disclose to you:

• The categories of Personal Information we collected about you;
• The categories of sources for the Personal Information we collected about you;
• Our business or commercial purpose for collecting or selling that Personal Information;
• The categories of third parties with whom we share that Personal Information;
• The specific pieces of Personal Information we collected about you (also called a “data portability request”); and
• If we disclosed your Personal Information for a business purpose, two separate lists disclosing:
• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that King & Spalding delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, which may require collection of additional information from you, we will delete and direct our service providers to delete your Personal Information from our records, unless an exception applies.  We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech ensure the right of another data subject to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with data subject expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information.  You may also make a verifiable request on behalf of your minor child.  You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• 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 Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  Making a verifiable request does not require you to create an account with us. We will only use Personal Information provided in a verifiable request to verify the requestor’s identity or authority to make the request.  We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 90 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.  Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information 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 verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  We will not discriminate against you for exercising any of your CCPA rights. If you exercise any of your CCPA rights, we will not take any of the following actions unless permitted by the CCPA:

• Deny you services;
• Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of services; or
• Suggest that you may receive a different price or rate for services or a different level or quality of services.

California residents intending to exercise the access, data portability, or deletion rights described above should submit a verifiable request to us by either:

• Calling us tollfree at 1-833-795-0354; or
• Visiting King & Spalding’s Data Subject Rights Portal.

“SHINE THE LIGHT”

California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.  California residents can make such a request by clicking this link.

Rights in the EEA and UK and other jurisdictions which have adopted similar laws
If you are located in the EEA, the UK or in other jurisdictions which have adopted similar laws, you may have certain rights as an individual under privacy laws applicable in those jurisdictions. This includes if your relationship with King & Spalding is as a client or in any other capacity as an individual with whom we deal. It includes individuals within client organisations, or individuals in third-party organisations. For example, European data protection legislation provides individuals with the right to lodge a complaint with a supervisory authority.

RIGHT TO BE INFORMED
This Privacy Notice sets out how we use your Personal Information and gives you information about how you can exercise any of your rights in accordance with applicable privacy laws.

RIGHT OF ACCESS
You may be entitled to ask us for a copy of any Personal Information which we hold. This right is known as a ‘Subject Access Request.’

We will normally send you a copy of the Personal Information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the Personal Information that you request. There is usually no charge; but in exceptional circumstances we may charge but will discuss this with you if those circumstances apply.

RIGHT TO RECTIFICATION
If the Personal Information we hold about you is inaccurate, you may request rectification. The Personal Information will be checked, and, where appropriate, inaccuracies will be rectified.

RIGHT TO ERASURE
In certain circumstances, you may be entitled to ask us to erase your Personal Information.

RIGHT TO DATA PORTABILITY
In certain circumstances, you may wish to move, copy, or transfer the electronic Personal Information that we hold about you to another organization.

RIGHT TO OBJECT
You may object to your Personal Information being used for direct marketing.

You may object to the continued use of your Personal Information in any circumstances where we rely upon consent as the legal basis for processing it.

Where we rely upon legitimate interests as the legal basis for processing your Personal Information, you may object to us continuing to process your Personal Information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your Personal Information, we may continue to do so. In that event, we will let you know the reasons for our decision.

RIGHTS RELATED TO AUTOMATED DECISION-MAKING INCLUDING PROFILING
We will not use your Personal Information in connection with any automated decision-making process.  We use limited contact information to carry out certain business development profiling activities to support and grow our business.  When doing so, we rely upon our legitimate interests as the lawful basis for processing your Personal Information and you may exercise the above rights if you do not wish us to process your Personal Information in this way.

Rights in Australia
If you are located in Australia, you may have certain rights as an individual under privacy laws applicable in that jurisdiction.  Provided that we are not subject to confidentiality obligations or some other restriction to our giving access to the information, you may contact us to access, correct or update your Personal Information.

To exercise the rights in relation to your Personal Information set out in this section, click here.

Children’s Rights
Our website is not intended for children under 16 years of age. No one under age 16 should provide any Personal Information to us through the Site. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not access, use, or provide any information on the website or on or through any of its features. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any Personal Information from a child under 16, please contact us.