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Last updated: March 9, 2022

This privacy notice and cookie policy explains how Procopio, Cory, Hargreaves & Savitch LLP (“Procopio”, “we”, “our”, “us”) processes personal information in the course of operating our business, particularly with regard to our marketing and business development practices, including how we process personal information we collect from visitors to and users of (“Users”, “you”, “your”) our website hosted at www.procopio.com (the “Site”) and how we use cookies on the Site. This privacy notice concerns our processing of personal data of Users based in the European Union where we are offering goods or services to you in the EU or where our Site may be used to monitor Users’ behavior as far as it takes place in the EU. Information for California residents about the California Consumer Privacy Act (CCPA) is available here. Please note that this privacy notice has general application to Users from anywhere in the world, except where noted, for example in the section “Users’ rights in relation to personal data,” which shall not apply to Users located outside of the EU.

This privacy notice and cookie policy does not apply to personal information Procopio collects 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 engagement agreements and professional responsibilities.

This privacy notice and cookie policy forms part of and is incorporated into the Terms of Use Agreement applicable to the use of the Site, which are set out in the Site’s Disclaimer wording, available here.

Procopio, Cory, Hargreaves & Savitch LLP (a limited liability partnership, registered in California, USA) is the ‘data controller’ of your personal data for purposes of the EU General Data Protection Regulation and as it was saved into UK law by virtue of section 3 of the UK’s European Union (Withdrawal) Act 2018 and the UK Data Protection Act 2018 (collectively hereinafter referred to as the “GDPR”). Procopio is a ‘data controller’ subject to the GDPR only insofar as we are offering goods or services to individuals in the EU or UK or where our Site may be used to monitor individuals’ behavior as far as it takes place in the EU or UK.

We may amend this page from time to time. You should check this page periodically for any changes.

How we collect Users’ information

When you use the Site, we collect your personal data in the following ways:

  • When you access and navigate around the Site (please see the Cookie Policy below);
  • When you communicate with us by email or via the Site, for example when you request support or submit an inquiry; and
  • When you sign up to receive our newsletters and other updates.

Where you provide us with personal information relating to others (for example, your colleagues, clients or other contacts), we understand that you are authorized to provide that information to us, and that you have provided this privacy notice and cookie policy to them, as appropriate.

The types of information we collect

We may collect the following types of personal data about Users of the Site:

Information You Provide Directly

  • Unique identifiers that we use to identify you as a unique individual, including names and contact details, such as postal addresses, email addresses and telephone numbers, or bar license numbers;
  • Other information that you provide through the Site, for example in messages, forms or in emails, including company or organization details and information about any legal services that Users seek;
  • Information that may be about you, but that may not identify you as a unique individual, including your zip code;
  • We may also collect ‘sensitive personal data’, for example, information concerning health and medical conditions but only where Users volunteer this information in a message, form or email to us.

Information Collected Automatically

  • Information about Users’ browsing activity collected through the use of cookies including details of your domain name, location and internet protocol (IP) address, operating system, browser version, language, the content viewed during a particular browsing session, and how long a User stayed on a particular page. Please see the Cookie Policy below.
  • We may also use web beacons or tracking pixels embedded in web pages or email messages, which may tell us whether you visited a particular web page or opened an email.

The legal grounds and purposes for processing Users’ information and how we use it

(i) We may process your personal data because it is necessary for our or a third party’s legitimate interests. Our “legitimate interests” include our interests in operating our firm and the Site in a client focused, efficient and sustainable manner.

In this respect, we may use your personal data for the following:

  • to assess the information that you provide through the Site (for example in messages, forms or in emails) and to find out more about you before contacting you in response, where appropriate;
  • to interact with you (for example, to send you promotional material, event invitations, or answer inquiries about our services);
    to interact with potential clients (for example through Procopio Business Advisors, LLC (PBA));
  • for record keeping purposes, so that we have a record of the inquiries we receive through the Site;
  • outsourcing selected website administration functions to third parties for the purposes of the efficient management of the Site;
  • to monitor and evaluate the performance and effectiveness of our services and the Site, including by training our staff or monitoring their performance, and to administer, support or improve the Site.

(ii) We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data in order to assist with investigations (including criminal investigations) carried out by the police, the government, regulators, or other competent authorities, where those authorities are acting in compliance with the law.

(iii) We may also process your personal data for additional reasons where:

  • it is necessary for reasons of substantial public interest (for example, where the due diligence checks we carry out involve our processing data relating to criminal convictions and offences);
  • it is necessary for the establishment, exercise or defense of legal claims (for example, to protect and defend our rights or property include the Site and its content); and
  • we have your specific or, where necessary, explicit consent to do so (for example, where we process sensitive personal data concerning your health or medical conditions because you have provided this in communications by email or through the Site).

Sharing Users’ information with others

Procopio does not sell your personal information, and we have not done so within the past twelve (12) months.

For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with certain third parties, including:

  • our employees, agents and contractors where there is a legitimate reason for their receiving the information, including:
    • those of our staff, attorneys, and consultants who may provide or offer to provide services to you in response to a request for support or an inquiry made to us;
    • providers of outsourced services to us (for example, any third party we engage to administer the Site on our behalf);
    • PBA, a wholly owned subsidiary of Procopio providing support to our clients in non-legal services, including incubator, finance, risk assessment, and governance;
    • Procopio Real Estate Services, Inc., a wholly owned subsidiary of Procopio providing non-legal real estate brokerage services;
  • internal and external auditors;
  • with a third party in a business transaction, in the event that all or part of Procopio is sold, merged, dissolved, acquired, or involved in a similar transaction which involves the transfer of the Site.

Transferring Users’ information outside of Europe

This section is for Users located in Europe.

In the course of interacting with you, we will transfer your personal data outside of the UK and the European Economic Area (“EEA”), principally to Procopio’s offices and servers in the United States; this means that your personal data will not have the automatic protection of European data protection laws (including the GDPR) which apply in the UK and the EEA. In these circumstances, in order to ensure that your personal data continues to have adequate protection when it is transferred out of the EEA, your personal data will only be transferred on one of the following bases:

  • where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (for example, standard data protection clauses adopted by the European Commission);
  • a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
  • there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent).

You can obtain more details of the protection given to your personal data when it is transferred outside the UK or EEA by contacting us using the details set out below.

How long Users’ information is kept

We will retain your personal information for as long as we are interacting with you, and for as long as permitted or required for legal and regulatory purposes after the last such interaction between you and us.

Users’ rights in relation to personal data

This section is for Users located in Europe. For California residents, please visit our Privacy Notice for California Residents, available here.

Under the GDPR, you have the following rights in relation to our processing of your personal data. Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

  • to obtain access to, and copies of, the personal data that we hold about you;
  • to require us to correct the personal data we hold about you if it is incorrect;
  • to require us to erase your personal data in certain circumstances;
  • to require us to restrict our data processing activities in certain circumstances;
  • to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on you;
  • to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.

Note: If you have given your consent and you wish to withdraw it, please contact privacy@procopio.com using the contact details set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.

If you are not satisfied with how we are processing your personal data, you can make a complaint to a data protection supervisory authority.

Contact us

If you have any queries about this privacy notice or how we process your personal information, or if you wish to exercise any of your rights under applicable law, you may contact our team:

Cookies

The Site uses cookies. A “cookie” is a small text file which is sent by our Site’s server and stored on your computer or other device when you access the Site. These cookies are used for the purpose of improving your experience of the Site by remembering your preferences, the places you have visited, and other information that you have provided to us. When you use the Site, you will be asked to confirm whether you agree to the Site using cookies and, if you accept, we will store cookies on your device. You can if you wish change the cookies settings on your device to refuse cookies. However, if you do this, or if you reject our request to use cookies when you visit our Site, you may be unable to access certain parts of the Site and/or you may not be able to benefit from the full functionality of the Site.

We use the following cookies for the following purposes:

  • Essential Cookies: these are essential in order to enable you to move around the Site and use its features, for example to remember which page of the Site you have previously visited during the same session, so that you can quickly move backwards and forwards between those pages.
  • Performance and Analytics Cookies, including Google Analytics: these keep track of the pages of the Site that you visit and the content you access, so that we can determine which content is most popular and improve the performance of the Site. These cookies record only anonymous statistical data and do not collect any personal information that could identify an individual User.
  • Functionality Cookies: these remember the choices you make, such as language options or the region you are in. These cookies help to make your visit to the Site more personal and are deleted automatically when you close your browser or when your browsing session expires. To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, please visit www.allaboutcookies.org.

To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, please visit www.allaboutcookies.org.

Please see the table below for additional details on the cookies we use.

Cookie name Default expiration time Description
_ga 2 years Used to distinguish users.
_gid 24 hours Used to distinguish users.
_ga_<container-id> 2 years Used to persist session state.
_gac_gb_<container-id> 90 days Contains campaign related information.
__utma 2 years from set/update Used to distinguish users and sessions.
__utmt 10 minutes Used to throttle request rate.
__utmb 30 mins from set/update Used to determine new sessions/visits.
__utmz 6 months from set/update Stores the traffic source or campaign that explains how the user reached the site.
__utmv 2 years from set/update Used to store visitor-level custom variable data.