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PRIVACY STATEMENT

1.1 Your Privacy

a. Curtis, Mallet-Prevost, Colt & Mosle LLP (a Limited Liability Partnership incorporated in New York, USA) and associated offices of Curtis, Mallet-Prevost, Colt & Mosle LLP practicing under the Curtis, Mallet-Prevost, Colt & Mosle name in other jurisdictions (collectively “Curtis”), respect your concerns about privacy. This Privacy Notice describes the types of information we collect, how we may use that information and with whom we may share it.

b. Curtis’s participation in the EU-U.S. Privacy Shield and the U.S.-Swiss Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Union, European Economic Area, and Switzerland is currently pending final certification.  We have committed to adhere to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, redress and enforcement (the “Privacy Shield Principles”). To learn more about the Privacy Shield program, please visit http://www.privacyshield.gov.  Upon final certification, you can view Curtis’s certification at the same address.

c. With respect to human resources data received from European Union member countries and Switzerland, Curtis commits to cooperate with the EU Data Protection Authorities and/or the Swiss Federal Data Protection and Information Commissioner, as applicable, in conformity with the Supplemental Principles on Human Resources Data and the Role of the Data Protection Authorities/the Role of the Federal Data Protection and Information Commissioner and will comply with any advice given by such authorities.

d. Your use of our website constitutes your acceptance of the terms of this Website Privacy Notice. In particular, by using our website you consent to our collection, use, retention, disclosure and transfer of your information and our use of cookies, all as described below.

1.2 Information We Collect

a. Anonymous Browsing. You are able to browse the non-password-protected sections of Curtis’s website without actively providing us with your personal information. We do not collect personal information when you browse, such as your email address. However, when you access our website your computer’s browser may automatically provide us with certain information, including information about your computer’s browser type, operating system and IP address, as well as your access date and time and your referring and exiting URLs.

b. Registration and Personal Information. In order to access certain areas of our website, register for Curtis-sponsored events, sign up for news, alerts or publications from Curtis, submit your resume or other information to apply for a job with Curtis, contact us or obtain further information from us via our website, we may ask you to provide information about yourself, including your name, address, telephone number, email address, organizational affiliation and certain other information that Curtis may use to identify you. If you choose not to provide such information, you may not be able to access certain areas of Curtis’s website or to receive information that you have requested from Curtis.

c. Cookies. Like many organizations, Curtis’s web servers (computers that host websites) place a "cookie" (a small data file) on the hard drive of your computer when you first connect to our site.

d. Web Beacons. This website may use a technology known as “web beacons” (also known as Internet tags, pixel tags and clear GIFs) that allow this website to collect web log information. A web beacon is a graphic on a web page or in an e-mail message designed to track pages viewed or messages opened. Web log information is gathered when you visit our website. The webserver automatically recognizes some non-personal information, such as the date and time you visited our site, the pages you visited, the website you came from, the type of browser you are using, the type of operating system you are using, and the domain name and address of your Internet service provider. We may also include web beacons in promotional e-mail messages in order to determine whether messages have been opened.

e. Do Not Track Signals. Curtis does not track its users over time or across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

f. This website is not intended for, or designed to attract, individuals under the age of 18. We do not knowingly collect personal information from any individual under the age of 18. If you are under the age of 18, do not provide personal information of any kind.

1.3 Use of Information

a. Information that is provided by your computer when you browse our website is used by Curtis solely for internal purposes (such as evaluation of site use, assessment and improvement of site performance and improvement of the functionality and services that we are able to offer) and is not used to target individuals for marketing unless paragraph 1.3b below applies. Moreover, we do not use cookies to collect and distribute information to third parties for marketing purposes. 

b. Where you register with us and provide information about yourself, we will use your information for the purposes for which it was provided, which may include contacting you and providing you with the information that you have requested from Curtis (but we will refrain from doing so without your express consent in jurisdictions which so require). We may also use your information to keep you informed about events, publications and services provided by Curtis that may be of interest to you. We will give you the opportunity to opt out of receiving such direct marketing communications. 

c. We may share your information among Curtis-affiliated entities and subsidiaries. We may also share your personal information with our agents or contractors in connection with services that these individuals or entities perform for Curtis. These agents or contractors are not authorized by us to use or disclose this information except as necessary to provide services for Curtis. We may, for example, provide your information to agents or contractors for hosting our databases, for data processing services, for processing online registration forms for events, or so that they can mail you information you requested. Curtis has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Curtis shall remain responsible and liable under the Privacy Shield Principles if its agent processes such personal information on Curtis’s behalf in a manner inconsistent with the Privacy Shield Principles, unless Curtis proves that it is not responsible for the event giving rise to the damage.

d. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use information you have provided through this website in a manner that is consistent with this Website Privacy Notice.

e. We may disclose information we have about you (i) if we are required to do so by law or pursuant to legal process, (ii) in response to a request from law enforcement authorities or other government officials, including to meet national security requirements, or (iii) when we believe disclosure is reasonably necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or illegal activity.

1.4 International Transfers of Information

We may transfer the personal information we collect through this website to the United States and to other countries in which we do business, which may not have the same data protection laws as the country in which you reside. In cases of transfers from the European Union, the European Economic Area or Switzerland to the United States, information is transferred, stored and processed in accordance with Privacy Shield Principles.

1.5 How We Protect Your Information

We maintain administrative, technical and physical safeguards for the website designed to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the information we collect through our website. However, we cannot ensure or warrant the security of any information you transmit to the website or to us.

1.6 Reviewing and Updating Your Information

You have the right to request a copy of all personal data which we hold in relation to you, and to have it corrected, updated or removed from our files. All such requests should be emailed to privacy@curtis.com.

2. Registration 

2.1 Registration Information

Access to certain areas of Curtis’s website may require you to register by providing your e-mail address and certain other information. By registering, you are representing that you are at least 18 years old and that you are able to enter into a valid agreement with Curtis. 

2.2 Codes

Upon registration, you will either select or receive from us a Login ID and a unique Password ("Codes"). You will be solely and fully responsible for the security of your Codes, and for any and all actions taken using them. Your Codes are for your personal and individual use only and should not be disclosed to any other person.

2.3 Modification or Termination of Codes 

You may modify your Codes at any time by emailing a request to privacy@curtis.com. Curtis reserves the right to suspend or terminate your Codes if it reasonably believes that your Codes are being used to engage in conduct that is inappropriate or in breach of this Website Privacy Notice. 

2.4 Cancellation of Registration

You may cancel your registration with Curtis’s website by emailing a request to privacy@curtis.com, providing your correct Login ID and Password with a statement to the effect, "Please terminate my registered user status for the Curtis website" and indicating "Cancel Registration" in the subject line. After receiving such request, Curtis will deactivate your Codes. 

2.5 Additional Services and Links to Other Sites

From time to time, we may provide links to other websites for your information or convenience or offer additional services through separate websites linked to this website. These websites operate independently from our website and may be subject to alternative terms of use, including terms concerning use of your personal information. We have not reviewed these third party sites and do not control and are not responsible for any of these sites, their content or their privacy policies. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third party sites listed on our website, you do so at your own risk. 

2.6 Withdrawal of Services 

Curtis reserves the right to withdraw the Curtis website or to remove any content without notice at any time and for any reason. 

3. Updates to Our Privacy Notice

We may update or change this Website Privacy Notice. The “Effective Date” at the top of this page states when this Website Privacy Notice was last revised. Any change to this Website Privacy Notice will become effective when we post the revised Website Privacy Notice on our website. Keep in mind that your use of our website means that you accept our Website Privacy Notice.

If any change may materially and negatively affect the privacy of your personal information, we will use reasonable efforts to notify you in advance and give you a reasonable period of time to object to any changes.

We encourage you to periodically review this Website Privacy Notice to stay informed about how we collect, use, and share personal information.

4. How to Contact Us

If you have any questions or complaints about our Website Privacy Notice or our Privacy Shield-related (or general privacy-related) practices, please contact us by:

Emailing privacy@curtis.com

or 

writing to us at:

Curtis, Mallet-Prevost, Colt & Mosle LLP
101 Park Ave
New York, NY 10178
Attn: General Counsel

5. Disputes

5.1 Disputes Generally

We take your privacy concerns seriously. If you believe that Curtis has not adhered to this Privacy Policy, please contact Curtis as described in Section 4 above. In your correspondence, please describe in as much detail as possible the ways in which you believe that this Privacy Policy has not been complied with. We will respond to you within 45 days of receipt of your correspondence and will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

5.2 Dispute Resolution

Curtis has further committed to refer unresolved disputes relating to the use of its website or unresolved privacy complaints, including those arising under the Privacy Shield Principles, to an independent dispute resolution body based in the United States, JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Curtis, please visit the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. This independent recourse mechanism by which your complaints and disputes can be investigated and expeditiously resolved will be provided at no cost to you.

EU citizens may report privacy complaints directly to their local Data Protection Authorities. Swiss citizens may report privacy complaints directly to the Swiss Federal Data Protection and Information Commissioner. You may also contact us to be directed to the relevant contacts.

As a Privacy Shield participant, Curtis commits to binding arbitration at the request of an individual to address any complaint relating to our privacy notice or our information practices that has not been resolved by other recourse and enforcement mechanisms.

6. Enforcement

Curtis conducts periodic self-assessments to verify that the attestations and assertions it makes about its privacy practices are true and that such privacy practices have been implemented as presented. Curtis will take steps to remedy any problems arising out of failure to comply with the Privacy Shield Principles.

The Federal Trade Commission has jurisdiction to investigate claims against Curtis regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy.

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