Description and purposes of the processing

When visiting our website, your browser will contact our webserver to retrieve the sites you wish to visit. In this context, Personal Information such as your IP address is transferred by your browser (i.e. by HTTP/S requests) to us. This connection information is processed by our webserver to enable access to and the display of our website.

Our webserver automatically saves a record of the pages you visited (so-called ‘logfiles’ or ‘session records’). We use these logfiles to ensure the security of our website, in particular to prevent unauthorised interference with it, and to enable us to exercise our legal rights and obligations in regard to such unauthorised interference.

Furthermore, we analyse session records to optimise our website. The results cannot be linked to an individual.

Methods of Processing

We may process your Personal Information using the following methods:

• Direct transmission. You may provide us with your Personal Information by filling in forms or by post, telephone, email or other means, including information that may be provided through:
  • registering an enquiry on our website;
  • subscribing to any newsletters (including with our Alumni Network) or events;
  • emailing us using any Contact form;
  • participating in discussion forums or other social media activities on our website;
  • contacting us to report a problem with our website.

Recipients

Our IT department has access to logfiles and will pass them on to other internal or external recipients including to the relevant authorities if necessary to exercise our legal rights regarding any unauthorised interference with our website.

Our website is hosted on our behalf by the hosting services provider Episerver Inc. (542 Amherst Street, Route 101A, Nashua, NH 03063, USA)

Retention period

Logfiles are normally erased after 90 days. They may be stored for a longer period if necessary for the above-mentioned purposes, including for the exercise of our legal rights.

All other Personal Information is erased immediately after processing the HTTP/S request.

Description and purposes of the processing

Our information hubs, collaborative platforms, legal technology solutions and other applications (“Solutions”) offer a wide range of resources and alternative ways to deliver our services on a particular Matter, primarily to our clients in the course of our business relationship with them but also to other parties. As a part of our delivery of legal services, we may use AI, where appropriate, including to support with document review, legal research and data analysis.

We will process personal information such as names and e-mail addresses to administer and monitor access to (and use of) these Solutions.  In order to tailor and further optimise the user experience, the functionalities and operation of these Solutions, and the information provided to you, we may also process personal information regarding your specified preferences, if any, and in some instances information regarding your use of our Solutions. We may also process this personal information for business development purposes and to troubleshoot, develop and improve our Solutions.

When you share personal information with us using certain Solutions in relation to a Matter, we will process that information, including Matter Information, for the purposes set out in section 3 of this Notice below.

We may also use personal information for business development purposes and to troubleshoot, develop and improve our Solutions.

Method of Processing

We may process your Personal Information using the following methods:

• Direct transmission. You may provide us with your Personal Information by filling in forms or by post, telephone, video conference, email or other means, including information that may be provided through:
  • Submitting a request form to be registered to a Solution;
  • emailing us using any contact form;
  • communicating with us via a videoconferencing or chat function of a Solution.

Recipients

Our internal business development and IT departments have access to and process registration and usage information for the provision and maintenance of your user account, for authentication purposes, for the optimisation of our information resources and business development initiatives and to enable the provision of Solutions to you.

Retention period

We retain Personal Information only for as long as there is a legal ground to do so, and will keep these legal bases under review. If there is no longer a legal ground for the information to be retained, we will erase Personal Information securely, or in some cases anonymise it.

Personal Information Processor

We are not the Personal Information Processor in respect of Personal Information processed within social media plug-ins. We do not have any access to the information collected and transferred to the social network provider. Any Personal Information processing is determined solely by the network service provider.

In the interest of transparency, we would like to inform you about the Personal Information processing in this context.

Description, method and purposes of the processing

To improve your user experience, our website includes social media plug-ins of the large social media networks Twitter, LinkedIn Google+. These plug-ins allow you to directly post links to and other content from our websites on the relevant network.

Upon you opening a website on which a social media plug-in is embedded, the respective social network provider will collect and process information on your visit to our website for its own business purposes. This processing is not initiated or controlled by us, but is a built-in feature of the respective social media plug-in.

For further information on the processing of Personal Information, please contact the respective social media provider or refer to their respective privacy policy:

• Google: policies.google.com/privacy
• Twitter: twitter.com/privacy
• LinkedIn: linkedin.com/legal/privacy-policy
• Xing: privacy.xing.com/en/privacy-policy

Recipients

We do not have access to, nor share, any Personal Information in this context.

For sharing of Personal Information by the social media provider, please contact the respective social media provider.

Retention period

We do not store any Personal Information in this context.

For storage of Personal Information by the social media provider, please contact the respective social media provider or refer to their respective privacy policy listed above.

Personal Information Processor

The Personal Information processing in the context of providing legal advice on a given Matter will ordinarily be controlled by the Personal Information Processor that is instructed and provides its services on that Matter. Where several Personal Information Processors work together on a Matter, they normally act as individual Personal Information Processors for the respective work done on that Matter by them, as they will ordinarily be providing their advice in respect of the relevant jurisdiction where they are based. If they should however act in a joint capacity, the relevant Personal Information Processor that is instructed on that Matter is designated as a single point of contact for natural persons under PIPL.

You can see here the Freshfields Entities through which we practise law in the relevant jurisdiction.

Description and purposes of the processing

We process Personal Information in relation to a Matter (“Matter Information”) for certain specific purposes, including:

• to provide our advice to our clients, and to handle the Matter;

• to comply with our applicable legal and regulatory obligations in the jurisdictions where we practise (e.g. to carry out conflict and Know Your Customer (or KYC) checks);

• for internal operational purposes (e.g. internal record keeping, know how and precedent management, accounting, billing and tax compliance);

• for business development, marketing and improvement of our services;

• to fulfil certain legal obligations (e.g. where applicable, disclosure obligations and compliance with court orders).

Whose Personal Information do we process in the course of handling a Matter?

Depending on the nature of the Matter, we may process Personal Information of various categories of individuals, including:

• clients and their respective officers, agents and staff;
• counterparties/contractual partners of our clients and their respective officers, agents and staff;
• other advisers, consultants and professional experts who are involved in the Matter and their respective officers, agents and staff;
• our partners and staff;
• third parties such as court officers, witnesses and other natural persons who are involved in the Matter.

What types of Personal Information are processed as Matter Information?

• Matter Information can include various types of Personal Information, depending on the nature of the Matter and the information that is provided to, or obtained by, us in the course of that Matter. The types of Personal Information that we typically process in relation to a Matter include client contact and communication information.
• Depending on the Matter, we may also process Sensitive Personal Information. We of course limit the processing of Personal Information and in particular Sensitive Personal Information to the necessary minimum.

Methods of Processing

We may collect Personal Information using the following methods:

• Direct transmission via email or other electronic means, by video conference or in person when you participate in any promotion, survey or event;
• Direct transmission via email or other electronic means, post, in person, over the telephone or by video conference or where a client has registered to use one of our Solutions, through use of the those Solutions;
• From other third parties involved in a matter via email or other electronic means, post, in person or by video conference;
• From public officials in the course of exercising their judicial function;
• From public registers or databases, court and public records; and/or
• From publicly available information on the internet or social media.

Recipients

In the course of our work on a Matter, as a global law firm we may, where necessary and subject to appropriate terms regarding confidentiality and data protection, share Matter Information:

• with our offices and associated undertakings that are part of Freshfields Bruckhaus Deringer across the world;
• if required, on a case-by-case basis, with other professional advisers including those working with us on a Matter (for example law firms from our “StrongerTogether” network);
• with other parties providing goods or services to us for the purpose of supporting our work on a Matter (e.g. providers of legal technology) or in connection with the administration of the activities of Freshfields Bruckhaus Deringer in the ordinary course of its business; and/or
• with our professional advisers and insurers where it is required for them to provide their services to us.

Retention Period

We retain Personal Information only for as long as there is a legal ground to do so, and will keep these legal bases under review. If there is no longer a legal ground for the information to be retained, we will erase Personal Information securely, or in some cases anonymise it.

Personal Information Processor

Personal Information processing activities in the context of global business development initiatives are generally handled by Freshfields Bruckhaus Deringer LLP.

Personal Information processing in the context of local business development initiatives are ordinarily controlled by the respective Freshfields’ Entity.

If different Freshfields Entities act as joint Personal Information Processors, Freshfields Bruckhaus Deringer LLP is the primary point of contact for natural persons under PIPL.

Description and purposes of the processing

In the conduct of our business we engage in different business development and related activities with current and potential clients and other relevant third parties. For these purposes, we process certain “business development information” such as:

• contact information (e.g. name, work address, telephone numbers, e-mail, position), communication data, and other business-related information;
• information on (marketing) preferences and fields of interest; and/or
• information on past participation in marketing initiatives.

This information is provided directly by, or obtained from, the relevant natural person or other business contacts and sources (e.g. business information services, public sources or registers).

Methods of Processing

We may collect Personal Information using the following methods:

• Direct transmission via email or other electronic means, by video conference or in person when you participate in any promotion, survey or event;
• From other third parties such as from business information services, public sources or registers via email or other electronic means, post.

Recipients

As a global firm in the conduct of our business, we share certain business development information within Freshfields Bruckhaus Deringer.

On a case-by-case basis, we may also share certain business development information with our business partners (for example law firms from our “StrongerTogether” network) and certain other parties that assist us with our business development activities in the ordinary course of our business (e.g. marketing services providers).

Retention period

We retain Personal Information only for as long as there is a legal ground to do so, and will keep these legal bases under review. If there is no longer a legal ground for the Personal Information to be retained, we will erase Personal Information securely, or in some cases anonymise it.

Personal Information Processor

Generally, Personal Information processing in the context of newsletters and update services (e.g. RSS news feeds and social media news feeds) are ordinarily handled by Freshfields Bruckhaus Deringer LLP.

Personal Information processing in the context of local newsletters or other update services are ordinarily controlled by the respective Freshfields’ Entity.

If different Freshfields Entities act as joint Personal Information Processors, Freshfields Bruckhaus Deringer partnership is the primary point of contact for natural persons under PIPL.

Description and purposes of the processing

If you have signed up or otherwise agreed to receive newsletters or other update services, we will process your contact information (e.g. name, e-mail) to provide those services to you.

To further optimise the user experience and in particular to tailor the information provided to you, we process information on your specified preferences, if any, and in some instances, follow your consumption of material (user statistics).

All newsletter activities and other update services serve marketing purposes and business development.

Methods of Processing

We may collect Personal Information using the following methods:

• Direct transmission via email or other electronic means, post, in person, over the telephone or by video conference.

Recipients

As a global firm in the conduct of our business, we share certain business development information within Freshfields Bruckhaus Deringer.

On a case-by-case basis, we may also share certain business development data with our business partners (for example law firms from our “StrongerTogether” network) and certain other parties that assist us with our business development activities in the ordinary course of our business (e.g. marketing services providers).

Retention period

We retain Personal Information only for as long as there is a legal ground to do so, and will keep these legal bases under review. If there is no longer a legal ground for the Personal Information to be retained, we will erase Personal Information securely, or in some cases anonymise it.

Personal Information Processor

Personal Information processing in the context of seminars, webinars and events is ordinarily controlled by the relevant Freshfields Entity offering the seminar, webinar or event.

Description and purposes of the processing

We offer seminars, webinars and events on a wide range of topics primarily to our clients in the course of our business relationship with them, but also to other registered parties. Seminars, webinars and events are part of our business development endeavours.

When you sign up for a seminar, webinar or event, we will process the registration Personal Information you provide, such as your name, role and contact details, to administer access to and present the respective seminar, webinar or event. We may also use registration and attendance Personal Information for purposes of business development and, where required by law to do so, to facilitate contact tracing in relation to COVID-19.

Method of Processing

We may collect Personal Information using the following methods:

• Direct transmission via email or other electronic means, by video conference or in person when you participate in any seminar, webinar promotion, survey or event.

Recipients

Registration and attendance information is processed by the relevant departments of the respective Freshfields Entity hosting and/or performing the seminar or webinar. It may also be processed by the internal business development departments of other Freshfields Entities. Lists of attendees may be provided to other attendees and, if required, by law to a contact tracing scheme in order to support efforts to help tackle COVID-19.

Retention period

We retain Personal Information only for as long as there is a legal ground to do so, and will keep these legal bases under review. If there is no longer a legal ground for the Personal Information to be retained, we will erase Personal Information securely, or in some cases anonymise it.

Personal Information Processor

Generally, Personal Information processing in the context of applications within Mainland China are handled by Freshfields Bruckhaus Deringer LLP.

If you apply for any roles outside of Mainland China, the Freshfields Entity to which you apply is responsible for that processing.

If different Freshfields Entities act as joint Personal Information Processors, Freshfields Bruckhaus Deringer LLP is the primary Personal Information Processor.

Description and purposes of the processing

You may send your application to us via e-mail, and we will process “applicant Personal Information” during the course of the application process, e.g.:

• name
• address;
• e-mail;
• education/qualifications/certifications; and / or
• any other Personal Information that you voluntarily provide us with your application.

We use that applicant Personal Information:

• to evaluate and select candidates;
• to set up and conduct interviews and tests;
• to evaluate and assess the results of those interviews; and / or
• if otherwise needed in the recruitment processes; as well as
• for the subsequent performance of the employment relationship, if successful.

We may carry out pre-employment vetting, including but not limited to credit reference and criminal record checks, address verification, confirmation of academic qualifications and requesting employer or other references if permitted by Applicable Laws (as mentioned above).

We may also use your information for reporting purposes when required to do so by law and for statistical purposes.

If your application (once completed) is unsuccessful, we may, with your consent, store your applicant information in our applicant pool (and process it further necessary) for the purpose of re-establishing contact with you. In this case, we may contact you in the future for suitable job advertisements that match your profile and invite you to other events that may serve to initiate an employment relationship. If you do not give your consent to the inclusion of your applicant Personal Information in our applicant pool this will not result in any disadvantages for you in any future application process.

Method of processing

We may collect Personal Information using the following methods:

• Direct transmission when you apply to a position via email;
• from recruiters or other third party suppliers that may be engaged by us;
• from publicly available information on the internet or social media.

Recipients

Internally, your Personal Information will only be processed by the Freshfields Entity or office which posted the job offer (and to which you have applied) and by the human resources/personnel department of that Freshfields Entity. Otherwise, your Personal Information will only be transferred or disclosed to other recipients if we are legally obliged to do so (e.g. to authorities).

Retention period

We retain Personal Information only for as long as there is a legal ground to do so, and will keep these legal bases under review. If there is no longer a legal ground for the information to be retained, we will erase Personal Information securely, or in some cases anonymise it.

Your basic contact information will be erased if you cancel your user account.

Your applicant information will be stored for a period sufficient to enable us to review your application. If your application is not successful or if you withdraw your application, your applicant Personal Information will be erased, unless further retention can be based on other legal grounds (e.g. for the exercise of our legal rights, or compliance with Applicable Laws (e.g. to exercise our legal rights or to comply with applicable law). You may also agree in a separate statement that your applicant information will be included in our applicant pool after completion of the application process. You can revoke your consent at any time by contacting us using the contact details provided. Your information will then be deleted immediately.

If your application is successful, any information provided through this recruitment system may be further processed for (or in relation to) your future employment with us. For further information on the processing of your Personal Information in the employment context, you will be able to refer to our internal privacy notice (PRC Staff Privacy Notice) accessible to our staff via our intranet (our “Data Protection Wiki”).

Personal Information Processor

The Freshfields Entity which organises the recruiting event is the Personal Information Processor of your Personal Information in connection with your registration/application for (and participation in) an event which may serve the purpose of getting to know each other and/or initiating a future employment relationship (“recruiting event”).

If different Freshfields Entities act as joint Personal Information Processors (e.g. with respect to the same recruiting event), Freshfields Bruckhaus Deringer LLP will be the primary Personal Information Processor.

Description and purposes of the processing

We always try to get to know new people and win them over for a job with us. Therefore, we regularly hold recruiting events. These can be events with a professional focus (e.g. presentations of our own activities or workshops) as well as events without a professional focus (e.g. participation in various events or restaurants visits).

You register and/or apply for participation in recruiting events via email or through one of our event platforms. The “participant Personal Information” you provide in this context, such as:

• name;
• contact details, such as address/or e-mail address; and
• any “applicant Personal Information” provided, such as training, qualifications and certificates, as well as other information required for carrying out the specific recruiting event, will be used and stored by us for the following purposes:
  • the assessment and selection of participants;
  • the preparation and implementation of the recruiting event; and
  • if necessary, the subsequent performance of an employment relationship.

We may also use your Personal Information for reporting purposes where required to do so by law and for statistical purposes.

If you have participated in a recruiting event or have already registered or applied to participate in such an event, we may, with your consent, include your participant and applicant Personal Information in our applicant pool for the purpose of contacting you again. In this case, we may contact you in the future with suitable job advertisements matching your profile and/or to invite you to further recruiting events. If you do not give your consent to the inclusion of your Personal Information in our applicant pool, this will not result in any disadvantages for you in any future application process.

Methods of Processing

Direct transmission via email or other electronic means, post, in person, telephone or by video conference.

Recipients

Internally, your Personal Information will only be processed by the Freshfields Entity that actually conducts the recruiting event (and to which you have registered or applied), and by the appropriate human resources department of that Freshfields Entity. Your contact details will be passed on to event organisers where necessary for registration or reservation at events (e.g. restaurant visits).

Otherwise, your Personal Information will only be transferred or disclosed to other recipients if we are legally obliged to do so (e.g. to authorities).

Retention period

We retain Personal Information only for as long as there is a legal ground to do so, and will keep these legal bases under review. If there is no longer a legal ground for the information to be retained, we will erase Personal Information securely, or in some cases anonymise it.

Your basic contact information will be erased if you cancel your user account.

Your applicant Personal Information will be stored for a period sufficient to enable us to review your application. If your application is not successful or if you withdraw your application, your applicant Personal Information will be erased, unless further retention can be based on other legal grounds (e.g. for compliance with Applicable Laws). You may also agree in a separate statement that your applicant information will be included in our applicant pool after completion of the application process but this is entirely voluntary and you may revoke your consent at any time by contacting our Personal Information Protection Representative using the contact details provided in section 12.

For further information on the processing of your Personal Information in the employment context, you will be able to refer to our internal privacy notice (PRC Staff Privacy Notice) accessible to our staff via our intranet (our “Data Protection Wiki”).

Personal Information Processor

The processing of Personal Information in the context of our social media tool for alumni (the “Freshfields Alumni Network”) on our website is generally controlled by Freshfields Bruckhaus Deringer LLP.

Information processed in the context of local alumni networks and newsletters are ordinarily controlled by the respective Freshfields Entity.

Description and purposes of the processing

The Freshfields Alumni Network is a network of valuable business contacts and enables you to keep in contact with us and your former colleagues. You may sign up to our Freshfields Alumni Network by filling out our registration form. We ask you to provide your contact information (name, private address and e-mail), current employment information (such as current company name, job title, business contact details) and information regarding your time at Freshfields (such as office and department at departure, role title). The Freshfields Alumni Network also serves recruiting purposes.

The registration form also provides the possibility to subscribe to different newsletters and updates. For further information on Personal Information processing activities in the context of these newsletters and updates, please see above under section 4.2.

Method of Processing

Direct transmission via email or other electronic means, post, in person, over the telephone or by video conference.

Recipients

We share the Personal Information, mentioned above, in particular contact information, with other Freshfields Entities.

Retention period

We retain Personal Information only for as long as there is a legal basis to so, and will keep these legal bases under review. If there is no longer a legal ground for information to be retained, we will erase Personal Information securely, or in some cases anonymise it. Generally, we erase your Personal Information in regard to your Freshfields Alumni Network as soon as possible after your withdrawal from this network.

Personal Information Processor

If you use the contact options on our website, the information is processed by the relevant Freshfields Entities if you contact them directly.

If different Freshfields Entities act as joint Information Processors, Freshfields Bruckhaus Deringer LLP is designated as a single point of contact for natural persons under PIPL.

Description and purposes of the processing

We offer you the possibility to contact us via e-mail or our contact form. We will process your Personal Information (such as your name, address, telephone number) to respond to your request and save them for potential further inquiries. Also the content of the communication will be processed by us for the purpose of responding to your request.

Method of Processing

Direct transmission via email or other electronic means, post, in person over the telephone or by video conference.

Recipients

We share the Personal Information, mentioned above, in particular contact information, with other Freshfields Entities.

Retention period

We retain Personal Information only for as long as there is a legal basis to so, and will keep these legal bases under review. If there is no longer a legal ground for Personal Information to be retained, we will erase Personal Information securely, or in some cases anonymise it. Generally, we erase your Personal Information in regard to your Freshfields Alumni Network as soon as possible after your withdrawal from this network.