Cozen O’Connor: Privacy Policy

Last updated: January 10, 2024

Thank you for using Cozen O’Connor. We are committed to protecting your privacy and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices (including our website at www.cozen.com (“Cozen website”), and mobile and web-based applications, and any other tools, products, or services provided by Cozen O’Connor that link to or reference this Privacy Policy) (collectively, the “Services”). The Services are owned and operated by Cozen O’Connor, a Pennsylvania professional corporation (“we”, “us” or “our”).

If you reside in the state of California, please click here to learn more about your privacy rights. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice for California Consumers, the Privacy Notice for California Consumers will prevail with respect to California Consumers (as defined below) only.

If you reside in the states of Virginia or Colorado, please click here to learn more about your privacy rights. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice for Covered State Residents, the Privacy Notice for Covered State Residents will prevail with respect to Covered Residents (as defined below) only.

This Privacy Policy does not apply to information collected from Canadian residents.

If you reside in a country in the European Economic Area or in Switzerland, please click here to learn more about your privacy rights. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice for European Residents, the Privacy Notice for European Residents will prevail with respect to European Residents (as defined below) only.

This Privacy Policy applies to information Cozen O’Connor collects as described throughout this Privacy Policy, as well as other information provided to us online or offline by third parties, when we associate that information with customers or users of the Services; however, it does not apply to information collected from our employees, contractors, or vendors.

CONSENT

By accessing or using our Services, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Services. Information gathered through the Services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the Services, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or Cozen O’Connor are deemed to occur in the United States, where our servers are located.

INFORMATION COLLECTED ON THE SERVICES

Personal Information

The majority of the information provided by Cozen O’Connor on the Services is available without Cozen O’Connor collecting any information that can identify or reasonably be linked to an individual (“Personal Information”), such as:

Names;
Personal or business addresses;
Email addresses;
Phone numbers;
Social Security numbers;
Bank account or credit card information (which you submit for payment purposes); and
Information contained in any image, photograph or profile you submit to us.

You can review almost the entire Services without disclosing any Personal Information. However, Cozen O’Connor does collect Personal Information that you may provide voluntarily. When you use our Services, we collect Personal Information. Some examples of times when Cozen O’Connor collects Personal Information include, but are not limited to, when you:

Submit an online request for information about Cozen O’Connor;
Ask us about employment opportunities and send us your resume or other employment experience information;
Complete a survey;
Send us an e-mail message;
Attend webinars;
Communicate with us to receive legal advice, legal services or services from Cozen O’Connor’s ancillary business units;
RSVP to an event; and/or
Interact with our marketing e-mails.

You have a choice as to whether to provide Cozen O’Connor with any Personal Information. Although you are not required to disclose any Personal Information to us, portions of the Services may not be available to you without your providing this information.

Due to the business and legal oriented nature of the Services, it is not designed to appeal to children under the age of 13. We do not knowingly request, receive or collect any information from children.

Non-Personal Information

The second type of information collected on the Cozen website is Non-Personal Information, such as the type of Web browser you use, your domain name and links you may have used to locate the Cozen website, but which otherwise does not identify you individually. We will not use Non-Personal Information to try to identify you, and if we associate any Non-Personal Information with information that personally identifies you, then we will treat it as Personal Information.

HOW WE USE THE INFORMATION COLLECTED

We do not sell or rent any information which we receive from the Services. Except as stated in this Privacy Policy, we will not share your Personal Information with anyone outside of Cozen O’Connor and those hired by Cozen O’Connor to perform work on its behalf.

Cozen O’Connor uses any Personal Information you provide in a limited number of ways. We may use your Personal Information for a number of reasons, including for the following purposes:

to provide you with information about Cozen O’Connor and its services;
to enhance or update the Services;
to provide legal advice, perform legal services or perform services from Cozen O’Connor’s ancillary business units;
to contact you if you are involved in a matter we are undertaking for a client, whether in your professional or personal capacity;
to process and assess potential conflicts of interest;
to carry out investigations, risk assessments and client due diligence;
to review, draft and disclose correspondence and other documents, including court documents;
to instruct third-parties on behalf of our clients;
for comparison/analytical purposes and to formulate legal opinions and provide advice;
to facilitate, make and receive payments to or from Cozen O’Connor;
to enhance or update the Services;
to advertise and market the services that we provide; and
for purposes authorized or required by applicable privacy legislation or other law.

We may also process your Personal Information for effective business management purposes which may involve the use of your Personal Information in the following (non-exhaustive) ways:

to engage and contact suppliers;
to carry out internal reviews, investigations, and audits;
to perform legal services or services from Cozen O’Connor’s non-legal business units;
for our internal record keeping;
to conduct business reporting and analytics;
to compile demographic statistics about users of the Services;
to help measure performance and improve our services;
for recruitment purposes;
for regulatory and legislative compliance and related reporting; and
for the prevention and detection of crime.

We may collect and disclose certain categories of Personal Information about third parties who do not directly interact with us, such as in the course of receiving or disclosing information from opposing counsel in legal matters.

We may also, on occasion, combine information about you that we have with information we obtain from other parties to enhance our ability to provide you with information about Cozen O’Connor and its services that we think may be of interest to you.

In addition, Cozen O’Connor may hire other companies to perform services on our behalf such as facilitating certain aspects of the Services or sending you email. These companies may be supplied with or have access to your Personal Information for the sole purpose of providing these services to us or on our behalf. Cozen O’Connor may also use third-party ad servers or ad networks to deliver ads to you on Cozen O’Connor’s behalf. These third-party ad servers may be supplied with or have access to your Personal Information for the sole purpose of providing these services to us or on our behalf. They also may also collect and use Non-Personal Information about your visits to the Cozen website in order to send advertisements that may be of interest to you.

On an aggregate basis only, we may collect Non-Personal Information about users of the Cozen website. Cozen O’Connor will never disclose any Personal Information as part of this aggregate information but we may lend, sell, share or otherwise disclose Non-Personal Information with others so we can perform research and provide the results to third parties, enhance and market the Cozen website, and conduct accounting and process record keeping functions. Additionally, we may use IP address information to count and track aggregate visits to the Cozen website, to help diagnose problems with our server, and to administer the Cozen website. Cozen O’Connor does not link IP addresses to anything personally identifiable so while a particular user’s session can be tracked, the user remains completely anonymous. We also may use this information to assist us in the ongoing technical development of the Cozen website.

Cozen O’Connor will make every effort to preserve user privacy but we may need to disclose Personal Information when required by law or if we have a good-faith belief that the action is necessary to comply with a pending judicial proceeding, a court order or legal process served on Cozen O’Connor or to protect our rights or the rights of others, to fight fraud, identity theft, to ensure the integrity and operation of our business and systems, or to protect the rights, property, or safety of Cozen O’Connor, its employees, members or others.

Also, in the unlikely event that of a bankruptcy or other insolvency event, or substantially all of our assets are acquired by another firm, Personal Information may then be transferred.

Cookies, Web Beacons and Clear Gifs

Cozen O’Connor also uses a feature of your browser called a “cookie.” Your cookie automatically identifies your computer - but not you - to our servers when you visit the Cozen website and allows us to correlate your computer with certain usage patterns which are stored in our log files. We use cookies to gather general, aggregate statistics about the overall popularity and usage of the Cozen website. Cozen O’Connor also uses more temporary cookies, often referred to as session cookies, to keep a user logged into the system and aid in the exchange of information between pages without loss of data. Such a cookie, however, is only stored for the current browsing session and is deleted once the browser is closed. Cozen O’Connor can also only read cookies from the Cozen website. Search for Cookies under your Web browser’s Help menu for more information on cookie management features available to you. If your browser is set to reject all cookies, the Cozen website may not function properly.

Cozen O’Connor may also collect information through the use of clear gifs (also called Web beacons and Web bugs) in selected email messages we send to you. These are tiny graphic files, not visible to the human eye, that are included in HTML-based emails and used to let us know which emails we send are opened. Clear gifs may also see or read cookies on your computer. When authorized by Cozen O’Connor, third parties specializing in monitoring aggregate statistical use of our site, with whom we contract, may use cookies, our web log files, web beacons, and other monitoring technologies to compile anonymous aggregate data.

Other Websites and Links

We may include links to other websites that we think will be of interest to you or operated by our business partners, affiliates, advertisers and others. These third parties have separate data collection and privacy practices independent from ours, and Cozen O’Connor cannot be responsible for their policies or activities. Please contact those third parties directly if you have questions about their privacy policies.

Accessing and Updating Information

Cozen O’Connor does not currently have an online method for users to delete their Personal Information contained in our database. However, you may change or update the Personal Information we have collected, request that we delete it, or request that we change how we use it by sending an email to privacy@cozen.com with your instructions. We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. Additionally, we may decline to delete Personal Information that is contained in litigation files or that we are required to retain by law or for audit or tax reasons. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Changes to this Privacy Policy

We encourage you to review our Privacy Policy not just the first time you visit the Services but periodically afterward since we may modify our Privacy Policy from time to time. The date of the last update of the Privacy Policy will always be posted below.

THIS PRIVACY POLICY WAS LAST REVISED ON: January 10, 2024

If we make any substantive changes to our Privacy Policy in the future with regard to how we use your Personal Information, we will incorporate those changes here. Your continued use of our Services after the changes are posted constitutes your agreement to the changes, both with regard to information we have previously collected from you and with regard to information we collect from you in the future. If you do not agree to the changes, please discontinue use of our Services.

International Users

Like almost every website, the Cozen website is accessible around the world. By visiting the Cozen website and providing your information, you acknowledge and agree that your Personal Information can be stored for the purposes identified in this Privacy Policy. We process and store your information in North America and your information may be stored on servers located outside your residential jurisdiction and which may have less stringent privacy practices than your own. If you access the Cozen website from outside the United States, your usage of the Cozen website constitutes consent to the transfer of your data outside of your country and to North America.

Security

We employ security measures that are designed to prevent unauthorized access to information that
you provide to us and that we collect online. However, we cannot guarantee the
security of your personal information.

Contacting Cozen O’Connor

Please feel free to share any comments and concerns with us. If you have any
questions about this Privacy Policy, please contact:

Camille Miller Cozen O’Connor 1650 Market Street Philadelphia, PA 19103

215-665-2000 Or by e-mail at: privacy@cozen.com

Privacy Notice for California Residents

This Privacy Notice for California residents (the “CA Notice”) supplements the information contained in our Privacy Policy and applies only if you reside in the State of California (you are a “California Consumer”).

For purposes of this CA Notice “Sell,” “Selling,” “Sale,” or “Sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to another business or a third party for monetary or other valuable consideration.

“Share”, “Shared,” or “Sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to a third party for Cross-context Behavioral Advertising, whether or not for monetary or other valuable consideration.

“Cross-context Behavioral Advertising” means the targeting of advertising to a consumer based on that consumer’s Personal Information obtained from activity across businesses or distinctly-branded websites, applications, or services, other than the business or distinctly-branded website, application, or service with which the consumer intentionally interacts. (In other words, if we send you an ad based solely on your interaction with us or our Services, this is not Cross-context Behavioral Advertising.)

“Sensitive Personal Information” means Personal Information that is not publicly available and reveals one or more of the following:

A consumer’s Social Security, driver’s license, state identification card, or passport number;
A consumer’s account log-in or financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
A consumer’s precise geolocation;
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
The contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication;
A consumer’s genetic or biometric data; or
Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.

“Verifiable Request” means that the identifying information provided by a consumer in connection with a request matches the Personal Information of the consumer already maintained by us or a third party identity verification service. Identifying information you can submit in order to permit Cozen O’Connor to verify your request may include your name, email address, and a secure confirmation code that we provide to you via email.

Information We Collect

In the past twelve (12) months, Cozen O’Connor has collected the following categories of Personal Information from California Consumers:

Account identifiers (names, date of birth, gender, email address, phone number, and user name and password);
Usage information (IP address, unique device IDs (such as account authentication token and password tokens) when you browse or interact with our Services, including through the use of cookies and other similar technologies;
Information contained in any image, photograph or profile you submit to us;
Communications, documents and other information you provide to us in the course of our client relationship;
Commercial and transactional information, including records of the products or services purchased;
Professional or employment-related information, such as information related to opportunities with Cozen O’Connor or its ancillary business units;
Preference information, account settings, the areas of the Services that you have visited or ways that you interact with the Services;
Information that you provide to us about a third party, such as that person’s name or email address;
Information which is not required to use our Services but that you choose to provide to us on an online form, or messages that you send through the Services; or
Any other information you provide to us in connection with legal and other services provided to you.

Additionally, in the past twelve (12) months, Cozen O’Connor has collected the following categories of Sensitive Personal Information from California Consumers:

Financial information (the bank account or credit card information that you provide to us in wiring or payment instructions and any insurance policy numbers you share with us in connection to the Services);
Classification characteristics (race, color, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)); and
Social Security, driver’s license, state identification card, or passport number when you apply for a job, summer internship, or any other employment related opportunities with Cozen O’Connor or its ancillary business units.

Cozen O’Connor obtains these categories of Personal Information and Sensitive Information directly from users when they sign up for the Services or visit the Cozen Website. For example, from forms you complete or products and services that you purchase. Additionally, Cozen O’Connor may collect categories of Personal Information or Sensitive Information from third parties who do not directly interact with us, such as in the course of receiving information from clients or opposing counsel in legal matters.

Use of Personal Information

Cozen O’Connor may use or disclose the Personal Information we collect for one or more of the following “Business Purpose(s):”

To fulfill or meet the reason you provided the information;
To provide our website, online services;
To manage our business operations and administer our client relationship;
To perform legal services and services from Cozen O’Connor’s ancillary business units;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
To respond to your requests under the California Consumer Privacy Act of 2018 (the “CCPA”), as amended;
For any other purpose described to you when we collect your Personal Information; and
For any other acceptable purposes as set forth in the CCPA.

Additionally, Cozen O’Connor may use or disclose the Sensitive Personal Information we collect for one or more of the following “Business Purpose(s):”

To fulfill or meet the reason you provided the information
To provide our website, online services;
To manage our business operations and administer our client relationship;
To perform legal services and services from Cozen O’Connor’s ancillary business units;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
To respond to your requests under the CCPA, as amended
For any other purpose described to you when we collect your Sensitive Personal Information; and
For any other acceptable purposes as set forth in the CCPA.

Unless we notify you otherwise, we will not collect additional categories of Personal Information, nor use the Personal Information we collect for any other materially different, unrelated, or incompatible purposes.

Retention of Personal Information

We retain each category of your Personal Information for no longer than is reasonably necessary for one or more Business Purposes, subject to your right to request we delete your Personal Information. Due to the nature of the services, it is not possible to predict the length of time that we intend to retain your Personal Information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain your Personal Information for one or more disclosed Business Purpose(s):

Whether not there is a retention period required by statute or regulations;
Pendency of any actual or threatened litigation for which we are required to preserve the information;
Generally accepted best practices in our industry; and/or
Pendency of applicable statutes of limitations for potential legal claims.

When we determine that it is no longer reasonably necessary to retain your Personal Information for one or more disclosed Business Purpose(s) based on the above criteria, we will delete your Personal Information.

Disclosure of Personal Information

Within the last 12 months Cozen O’Connor has disclosed your Personal Information as described in this CA Notice.

Cozen O’Connor discloses Personal Information to third parties for a Business Purpose. When we disclose Personal Information for a Business Purpose, we enter into an agreement with the receiving party that describes the purpose for disclosing the Personal Information, and that requires the third party to keep that Personal Information confidential and not use it for any purpose other than performing the services according to the agreement.

We may disclose your Personal Information with the following categories of third parties: (i) Service Providers (as described in the Privacy Policy); (ii) parties and related parties in legal matters; (iii) our clients, with respect to the provision of legal services or services from Cozen O’Connor’s ancillary business units; or (iv) other law firms, consultants or professional advisors that we work with to provide our legal services or services from Cozen O’Connor’s ancillary business units to a particular client.

In the past twelve (12) months, Cozen O’Connor has not Sold or Shared any Personal Information about its California Consumers.

Your Rights and Choices

If you are a California Consumer, you may request information about our collection, use, disclosure and Sale of your Personal Information over the past twelve (12) months, whether or not it was collected electronically. If you submit a Verifiable Request, we will disclose:

the categories of Personal Information we have collected about you; the categories of sources from which your Personal Information was collected; our Business Purpose or commercial purpose for collecting, Selling, or Sharing your Personal Information; the categories of third parties with whom we disclose that Personal Information; and the specific pieces of Personal Information we collected about you; and
if we Sold, Shared, or disclosed your Personal Information for a Business Purpose: what categories of Personal Information we Sold or Shared, and to which categories of recipients we Sold or Shared it; and what categories of Personal Information we disclosed for a Business Purpose, and to which categories of recipients we disclosed it to.

You also have the right to request that we delete any of your Personal Information that we collect or maintain by submitting a Verifiable Request. We may deny your deletion request if retaining your Personal Information is necessary for us or our Service Providers to:

Complete the transaction for which we collected your Personal Information, provide goods or services 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 consumer to exercise their right of free speech, 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 achievement of such research, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer 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.

You further have the right to request that we correct any of your Personal Information that is inaccurate by submitting a Verifiable Request. We will correct any inaccurate Personal Information pursuant to your request to the extent possible using commercially reasonable efforts. We may deny your correction request if the Personal Information is accurate.

Lastly, you have the right to request that we limit the use and disclosure of Sensitive Personal Information by submitting a Verifiable Request. If you submit such a Verifiable Request, we may continue to use or disclose your Sensitive Personal Information to:

Complete the transaction for which we collected your Personal Information, provide goods or services 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;
Use in a short-term and transient manner, including, but not limited to, to facilitate non-personalized advertising shown as part of your current interaction with the Services, but not including disclosure to third parties or use outside your current interaction with the Services;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you choose to exercise a privacy right under the CCPA, you have the right not to receive discriminatory treatment.

You may submit a Verifiable Request for the information listed above, or exercise any of your rights enumerated under this CA Notice, by emailing us at privacy@cozen.com, calling us at 833-200-7515, or by completing a form on our website. You may also submit a Verifiable Request on behalf of your minor child.

After we receive your Verifiable Request, we will provide to you, in writing and free of charge (unless your request is excessive, repetitive, or manifestly unfounded), the requested information for the 12-month period preceding your request. You can choose to have this information delivered to you by postal mail or electronically. We will try to respond to your verified request within forty-five (45) days of receipt, but if we require more time (up to another forty-five (45) days) we will inform you of the reason and extension period in writing. Please note that we are not required to comply with your request for information more than twice in any 12-month period. If applicable, our response will explain the reasons why we cannot comply with your request.

Cozen O’Connor does not and will not, without first obtaining your consent, Sell or Share Personal Information.

Should you choose to exercise any of the rights enumerated under this CA Notice, we will not:

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

However, please be aware that it may be a functional necessity for our Services to have Personal Information about you in order to operate, and we may not be able to provide some or all of our Services to you if you direct us to delete your Personal Information.

Privacy Notice for Covered Residents

This Privacy Notice for Covered Residents (the “Notice”) supplements the information contained in our Privacy Policy and applies only if you reside in the States of Virginia or Colorado (collectively, the “Covered States”) (a resident of any Covered States, a “Covered Consumer”). The Notice applies equally to Covered Consumers unless noted otherwise.

For purposes of this Notice “Sell,” “Selling,” “Sale,” or “Sold,” means the exchange of Personal Information for monetary or other valuable consideration by Cozen O’Connor to a third party. “Sell,” “Selling,” “Sale,” or “Sold,” does not include the following:

Disclosure of Personal Information to a third party that processes data on behalf of Cozen O’Connor;
Disclosure of Personal Information to a third party for purposes of providing a product or service requested by you;
Disclosure or transfer of Personal Information to an affiliate of Cozen O’Connor;
Disclosure or transfer of Personal Information to a third party as an asset that is part of a proposed or actual merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Cozen O’Connor’s assets; and
Disclosure of Personal Information that is intentionally made available by you to the general public via a channel of mass media without restricting the Personal Information to a specific audience.

“Sensitive Personal Information” means any of the following: (1) Personal Information revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or citizenship status; (2) genetic or biometric data that may be processed for the purpose of uniquely identifying an individual; (3) Personal Information from a person known to be under 13 years of age; or (4) precise geolocation data. If you are a Colorado Consumer, Sensitive Personal Information also includes Sensitive Data Inferences.

“Sensitive Data Inferences” means inferences made based on Personal Data, alone or in combination with other data, which are used to indicate an individual’s racial or ethnic origin; religious beliefs; mental or physical health condition or diagnosis; sex life or sexual orientation; or citizenship or citizenship status.

“Verifiable Request” means the identifying information provided by a consumer in connection with a request matches the Personal Information of the consumer already maintained by us or a third party identity verification service. Identifying information you can submit in order to permit Cozen O’Connor to verify your request may include your name, email address, and a secure confirmation code that we provide to you via email.

“Targeted Advertising” means displaying to a consumer an advertisement that is selected based on Personal Information obtained or inferred over time from the consumer’s activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests. “Targeted Advertising” does not include the following:

Advertising to a consumer in response to a consumer request;
Advertisements based on activities within our own websites or online applications;
Advertisements based on the context of a consumer’s current search query, visit to a website, or online application; or
Processing Personal Information solely for measuring or reporting advertising performance, reach, or frequency.

“Profiling” means any form of automated processing of Personal Information to evaluate, analyze, or predict personal aspects concerning an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

“Relevant Data Privacy Law” means the specific data privacy law of the state of which a consumer is a resident: the Consumer Data Protection Act (“CDPA”) for a Virginia Consumer and the Colorado Privacy Act (“CPA”) and Colorado Privacy Act Rules for a Colorado Consumer.

1. Information We Collect or Process

Cozen O’Connor has collected or processed the following categories of Personal Information from Covered Consumers:

Account identifiers (names, date of birth, gender, email address, phone number, and user name and password);
Usage information (IP address, unique device IDs (such as account authentication token and password tokens)) when you browse or interact with our Services, including through the use of cookies and other similar technologies;
Information contained in any image, photograph or profile you submit to us;
Communications, documents and other information you provide to us in the course of our client relationship;
Commercial and transactional information, including records of the products or services purchased;
Professional or employment-related information, such as information related to opportunities with Cozen O’Connor or our ancillary business units;
Classification characteristics (race, color, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information));
Financial information (the bank account or credit card information that you provide to us in wiring or payment instructions and any insurance policy numbers you share with us in connection to the Services);
Social Security, driver’s license, state identification card, or passport number when you apply for a job, summer internship, or any other employment related opportunities with Cozen O’Connor or its ancillary business units;
Preference information, account settings, the areas of the Services that you have visited or ways that you interact with the Services;
Information that you provide to us about a third party, such as that person’s name or email address;
Information which is not required to use our Services but that you choose to provide to us on an online form, or messages that you send through the Services; or
Any other information you provide to us in connection with legal and other services provided to you.

Cozen O’Connor obtains this Personal Information directly from users when they sign up for the Services or visit the Cozen Website. For example, from forms you complete or products and services that you purchase. Additionally, Cozen O’Connor may collect categories of Personal Information or Sensitive Information from third parties who do not directly interact with us, such as in the course of receiving information from clients or opposing counsel in legal matters.

The above-listed categories of Personal Information collected from Covered Consumers may include Sensitive Personal Information. By accessing or using the Services, you consent to the collection and processing of Sensitive Personal Information in the categories listed above. If you do not consent to the collection and processing of Sensitive Personal Information within these categories, please do not access or use the Services.

2. Use of Personal Information

Cozen O’Connor may use or disclose the Personal Information we collect for one or more of the following “Business Purpose(s):”

To fulfill or meet the reason you provided the information;
To provide our website, online services;
To manage our business operations and administer our client relationships;
To perform legal services and provide products and services from Cozen O’Connor’s ancillary business units;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
To respond to your requests under the Relevant Data Privacy Law;
For any other purpose described to you when we collect your Personal Information; and
For any other acceptable purposes as set forth in the Relevant Data Privacy Law.

3. Disclosures of Personal Information

Cozen O’Connor has disclosed your Personal Information as described in this Notice, including the following categories of Personal Information:

Cozen O’Connor discloses Personal Information to third parties for a Business Purpose. When we disclose Personal Information for a Business Purpose, we enter into an agreement with the receiving party that describes the purpose for sharing the Personal Information, and that requires the receiving party to keep that Personal Information confidential.

We may disclose your Personal Information with the following categories of third parties: (i) Service Providers (as described in the Privacy Policy); (ii) parties and related parties in legal matters; (iii) our clients, with respect to the provision of legal services or products and services from Cozen O’Connor’s ancillary business units; or (iv) other law firms, consultants or professional advisors that we work with to provide our legal services or products and services from Cozen O’Connor’s ancillary business units to a particular client.

In the past twelve (12) months, Cozen O’Connor has not Sold any Personal Information about its Covered Consumers or processed Personal Information about its Covered Consumers for Targeted Advertising.

4. Your Rights and Choices

If you are a Covered Consumer, depending on where you live, and subject to certain exceptions, you may have some or all of the following rights:

Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and the information about our data practices.
Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
Right to Opt Out of Targeted Advertising: The right to opt out of the processing of your Personal Information obtained from your activities for the purposes of targeted advertising. Please note that Cozen O’Connor does not process, use, share, or Sell your data for the purposes of Targeted Advertising.
Right to Non-Discrimination: The right to not receive discriminatory treatment for exercising your privacy rights.

If you submit a Verifiable Request, we will disclose whether we have collected or processed your Personal Information and allow you to access the Personal Information we have collected, to the extent we continue to retain the Personal Information. To the extent technically feasible, we will disclose this information to you in a readily usable format that allows you to transmit the data to another entity without hindrance. In the case of individuals located in Colorado, in the event that you make more than (1) request in any twelve (12) month period, we reserve the right to charge a fee prior to processing any such request(s).

You may also request that we delete any of your Personal Information that we collect or maintain by submitting a Verifiable Request. We may deny your deletion request if retaining your Personal Information is necessary for us or our Service Providers to:

Complete the transaction for which we collected your Personal Information, provide products or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Prevent or detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or investigate, report, or prosecute those responsible for such activity;
Debug products to identify and repair errors that impair existing intended functionality;
Engage in public or peer-reviewed scientific 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 achievement of such research, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Cooperate with law enforcement agencies concerning conduct or activities that we reasonably and in good faith believe may violate the law;
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.

You may request that we correct any of your Personal Information that is inaccurate by submitting a Verifiable Request. We will correct any inaccurate Personal Information pursuant to your request, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information. We may deny your correction request if the Personal Information is accurate.

If you choose to exercise a privacy right under the Relevant Data Privacy Law, you have the right not to receive unlawful discriminatory treatment. Should you choose to exercise any of the rights enumerated under this Notice we will not:

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

You may submit a Verifiable Request for the information listed above, or exercise any of your rights enumerated under this Privacy Notice for Covered Residents, by emailing us at privacy@cozen.com, calling us at 833-200-7515, or by completing a form on our website. You may also submit a Verifiable Request on behalf of your minor child who is under 13 years of age.

After we receive your Verifiable Request, we will provide to you, in writing, the requested information. You can choose to have this information delivered to you by postal mail, electronically. We will try to respond to your verified request within forty-five (45) days of receipt, but if we require more time (up to another forty-five (45) days) we will inform you of the reason and extension period in writing. If we decline to act on your request for any reason permitted under the Relevant Data Privacy Law, we will notify you of our decision within forty-five (45) day of receiving your request. If applicable, our response will explain the reasons why we cannot comply with your request.

If we deny your request or fail to act on it within the required time period, you may have the right to appeal this decision by submitting a new Verifiable Request in which you conspicuously note that you are appealing a previous decision. If you are a Virginia resident, we will respond to your verified request to appeal within sixty (60) days of receipt. If you are a Colorado resident, we will try to respond to your verified request to appeal within forty-five (45) days of receipt, but if we require more time (up to another sixty (60) days) we will inform you of the reason and extension period in writing. If applicable, our response will explain the reasons why we are denying your appeal, and any further steps that may be available to you.

Cozen O’Connor does not and will not, without first obtaining your consent, process your Personal Information for Targeted Advertising, Profiling, and/or Sale to third parties.

Privacy Notice for European Residents

If you reside in a country in the European Economic Area or in Switzerland (a “European Resident”), then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”)), and the following additional information is provided for your benefit.

Scope

This Privacy Notice (“GDPR Notice”) describes how Cozen O’Connor collects and uses your Personal Data in accordance with the GDPR and other applicable data protection and privacy legislation. It tells you what Personal Data we collect, why we need it, how we use it and what protections are in place to keep it secure.

Key Terms

“Cozen” “we” “us” and “our” mean Cozen O’Connor LLP and all of its affiliates (to the extent that they process Personal Data concerning persons (“Data Subjects”) in the European Union).

“Cozen Personnel” means Cozen’s prospective, present and past partners, employees, consultants and agency staff, and people connected to such persons.

“Personal Data” means information about individuals (including you), and from which such individuals could be identified.

“You” means individuals whose Personal Data we process including, but not limited to Cozen’s clients, Cozen’s client personnel, counter-parties, counter-party personnel, other solicitors/advisors, witnesses, suppliers, supplier personnel, job applicants and individuals to whom we send marketing communications. “You” does not include Cozen Personnel.

Data Controller

Cozen is the Data Controller in relation to your Personal Data and is committed to protecting the privacy rights of individuals, including your rights.

Data Protection Manager

Cozen is not required under the GDPR to appoint a Data Protection Officer and, following a detailed analysis does not consider it appropriate to do so on a voluntary basis. It has however, appointed a Data Protection Manager, (“DPM”) who is responsible for overseeing Cozen’s compliance with the GDPR and any other applicable data protection legislation and regulation.

The DPM can be contacted at GDPR@cozen.com.

How does Cozen obtain your Personal Data?

In some circumstances, we may obtain your Personal Data from you directly including through your use of this website or a job application but, more typically, we will obtain your Personal Data from a third-party source, for example, we may collect information from our clients/our clients’ personnel, agents and advisors, other law firms/advisors which represent you, the company for whom you work, other organisations/persons with whom you have dealings, government agencies, credit reporting agencies, recruitment agencies, information or service providers and publicly available records.

What about Personal Data which you provide to Cozen?

If you provide information to us about someone else (such as one of your associates, directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may process that information in accordance with this GDPR Notice.

What Personal Data does Cozen collect from and about you?

We collect and use different types of Personal Data about you, which will vary in type and detail depending on the circumstances and purpose of processing. Please consider the following illustrative and non-exhaustive examples:

Personal Data about you: name, address, date of birth, marital status, nationality, race, gender, preferred language, job title, work life and restrictions and/or required accommodations, possibly about your family life;
Personal Data to contact you at work or home: name, address, telephone, and e-mail addresses;
Personal Data which may identify you: photographs and video, passport and/or driving license details, electronic signatures;
Personal Data to process any payment we might need to make to you: bank account details, H M RC numbers and references (where applicable);
Personal Data to monitor your use of our website: IP address, traffic and location information, weblogs and other communication information.

Why do we need to collect and use your Personal Data?

We need to collect and use your Personal Data for a number of reasons, the primary purpose being to provide legal advice and services to our clients and which may involve the use of your Personal Data in the following (non-exhaustive) ways:

to contact you if you are involved in a matter we are undertaking for a client, whether in your professional or personal capacity;
to carry out investigations, risk assessments and client due diligence;
to analyse the practices of your employer or other organisations and/or persons with whom you have dealings;
to review, draft and disclose correspondence and other documents, including court documents;
to instruct third-parties on behalf of our clients; and
for comparison/analytical purposes and to formulate legal opinions and provide advice.

We may also process your Personal Data for effective business management purposes which may involve the use of your Personal Data in the following (non-exhaustive) ways:

to engage and contact suppliers;
to carry out internal reviews, investigations, audits;
to conduct business reporting and analytics;
to advertise and market the Services that we provide;
to help measure performance and improve our Services;
for recruitment purposes;
for regulatory and legislative compliance and related reporting; and
for the prevention and detection of crime.

What is Cozen’s legal basis for processing your Personal Data?

Under the GDPR, Cozen must identify a lawful basis for processing your Personal Data which may vary according to the type of Personal Data processed and the individual to whom it relates.

Performance of a contract with you (where applicable):

Cozen is entitled to process the Personal Data it requires in order to fulfil its obligations under its contract with you. This will be the relevant legal basis if you are an individual client or supplier/other individual with a direct contractual relationship with Cozen.

Legitimate interests of Cozen or a third-party:

We process some of your Personal Data on the basis that it is in our legitimate interests and/or the legitimate interests of a third-party to do so. This will primarily concern the processing of Personal Data that is necessary to provide legal advice and services to our clients. Cozen’s legitimate business interest in such instances is the proper performance of its function as an authorised and regulated provider of legal services and services from Cozen’s ancillary business units. Cozen’s clients’ also have a legitimate interest (and more general right in law) in obtaining legal advice and services.

Cozen’s broad interest in the provision of legal services and services from Cozen’s ancillary business units as a basis for processing your Personal Data, and our clients’ corollary interest in the receipt of such services, can be broken down into more discreet categories which may include, but are not limited, to:

the interest in contacting individuals relevant to Cozen’s work and our clients’ matters, which may involve the use of your Personal Data;
the interest in reviewing documents and correspondence that have been disclosed to Cozen, Cozen’s clients and third-parties which may contain your Personal Data;
the interest in reviewing and analysing all evidence available to Cozen and its clients, which may contain your Personal Data; the interest in adducing legal arguments, creating documents and correspondence, which may contain your Personal Data;
the interest in disclosing documents and correspondence, which may contain your Personal Data, to various parties in the furtherance of Cozen’s clients’ objectives;
the interest in instructing third-parties on behalf of Cozen’s clients;
the interest in receiving payment from Cozen’s clients and third-parties and to facilitate payments to and from Cozen’s clients and third-parties; and
in order to allow for all of the above, the secure management and storage of your Personal Data, within our IT environment and hard-copy filing systems.

Cozen may also process your Personal Data on the basis that it is necessary for its legitimate business interests in the effective management and running of Cozen which may include, but is not limited to: engaging suppliers and supplier personnel; ensuring that its systems and premises are secure and running efficiently; for regulatory and legislative compliance, and related auditing and reporting; for insurance purposes; for recruitment/hiring purposes; for marketing purposes; and to facilitate, make and receive payments.

Cozen does not consider that the processing of your Personal Data, on the basis that it is within Cozen’s legitimate interests (whatever such interests might be), is unwarranted because of any prejudicial effect on your rights and freedoms or your legitimate interests.

- Compliance with a legal obligation to which Cozen is subject:

In certain circumstances, Cozen must process your Personal Data in order to comply with its legal obligations. This might include, but is not limited to, Personal Data required: for tax and accounting purposes; for conflict checking purposes as required by the common law and Cozen’s regulators; and for Cozen to fulfil its compliance and other obligations under relevant legislation/regulation.

More information relating to legal bases for processing Personal Data can be found by contacting the DPM.

Special category and criminal records Personal Data

If Cozen processes your criminal records Personal Data or special category Personal Data relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, health data, biometric data or sexual orientation, we will obtain your explicit consent to those activities unless this is not required by law (because, for example, it is processed for the purpose of exercising or defending legal claims) or the information is required to protect your health in an emergency. Where we are processing Personal Data based on your consent, you have the right to withdraw that consent at any time. Direct Marketing We may use your contact details to send you marketing materials, provided we are permitted to do so by law. You always have the right to unsubscribe from any marketing. You can do so by clicking on the relevant link in the next email we send you, or by contacting the DPM using the details provided.

Who receives your Personal Data?

We may disclose your Personal Data to third-parties (outside of Cozen and Cozen Personnel) if, but only when, we have a legal basis to do. Such recipients include but are not limited to: co-counsel, other solicitors/barristers/experts/foreign law firms whom we instruct on your behalf; Courts, Cozen’s insurance brokers and underwriters; Cozen’s bank, auditors and accountants; Cozen’ outsourced IT providers and other suppliers; HMRC; the SRA; the Law Society; the other side/other parties on any given matter (lay and solicitor).

How do we protect your Personal Data?

We have security arrangements in place to guard against unauthorised access, improper use, alteration, destruction or accidental loss of your Personal Data. We take appropriate organisational and technical security measures and have rules and procedures in place to ensure that any Personal Data we hold is not accessed by anyone unauthorised to access it. We have in place, and abide by, a specific information security policy about the security standards used to protect your Personal Data.

When we use third-party organisations to process your Personal Data on our behalf, they must also have appropriate security arrangements, must comply with our contractual requirements and instructions and must ensure compliance with the GDPR and any other relevant data protection legislation.

Is your Personal Data transferred to “third countries” and, if so, what safeguards are in place?

In accordance with this GDPR Notice and the provisions of the GDPR, we may transfer your Personal Data to organisations located in “third countries” (those outside of the EEA). In addition to the security arrangements mentioned above in relation to our engagement of third-party organisations, where such transfers are required we will ensure that your Personal Data is adequately protected, for example, by using a contract for the transfer which contains specific data protection provisions (the “Model Clauses”) that have been adopted by the Data Protection Commission or a relevant data protection authority.

If you wish to see a copy of these Model Clauses, please contact the DPM.

How long will your Personal Data be retained by Cozen?

It is our policy to retain your Personal Data for the length of time required for the specific purposes for which it is processed by Cozen and which are set out in this GDPR Notice. However, we may be obliged to keep your Personal Data for a longer period, for example, where required by our legal and regulatory obligations or in order to ensure we have effective back-up systems. In such cases, we will ensure that your Personal Data will continue to be treated in accordance with this GDPR Notice, restrict access to any archived Personal Data and ensure that all Personal Data is held securely and kept confidential.

What are your rights?

The GDPR generally affords individuals a right to access their Personal Data, to object to the processing of their Personal Data, to rectify, to erase, to restrict and to port their Personal Data.

We have specific procedures in place in relation to Subject Access Requests (“SARs”) that you may be entitled to make. Put simply, a SAR is a request made by you which requires us to provide you with details of your Personal Data which we hold and process and a description of how we process it. Any questions or requests should be put in writing to the DPM.

There are exceptions to the rights of individuals in relation to their Personal Data and, particularly when we are processing your Personal Data for the purpose of providing legal advice to our clients, your rights may be limited. We will, at all times, respect your Personal Data and seek to be as transparent as possible but please be aware that, in some instances, we may be restricted from even acknowledging that we process your Personal Data.

How to make a complaint

If you are unhappy with the information provided in this GDPR Notice or have concerns about the way in which Cozen processes your Personal Data you may contact the DPM.