Privacy Notice

1. INTRODUCTION

Bracewell LLP and Bracewell (UK) LLP (collectively, "Bracewell" / "we" / "us" / "our") provide this Privacy Notice to inform you of our policy relating to the processing of your personal information. We take your privacy seriously and we are committed to protecting personal data that we receive from you. This Privacy Notice sets out the basis on which we will process your personal information. Please read it carefully to understand our practices regarding your personal information and how we will use it.   

If you reside in the EU, the data controller (as defined under EU data protection law) will be the Bracewell relevant entity with whom you engage.

Contacting us If you have any questions about this privacy notice, your personal information, or would like to exercise any rights that you may have in relation to your personal data, please contact us at privacy@bracewell.com.

2.   What types of data are protected

A. Personal data

This Privacy Notice applies to your personal data, which is any information relating to you as an identified or identifiable person. For purposes of this Privacy Notice, your personal data may also be referred to as personal information.

B. Special categories of personal data

We recognize that in certain contexts, we may collect personal data from one or more of the “special categories of personal data” (as defined under EU data protection laws) which are subject to a greater degree of protection. 

3. What Information we Process

The processing activities we engage in with respect to personal data you provide to the us depends on the nature of our exchanges with you.   

A. Personal information we process

We may process one or more of the following types of personal information, depending on the context:

Interactions with our website	Name Personal contact details (e.g., personal email address, personal address, telephone number(s)) Company contact details (e.g., company name, position, business email address, business address, telephone number(s))
Interactions as our client or as an aspect of the client engagement process	Name Personal contact details (e.g., personal email address, personal address, telephone number(s)) Company contact details (e.g., company name, position, business email address, business address, telephone number(s)) Information relating to the matter that is the subject of the engagement or potential engagement Information provided by you in support of or incidental to the engagement or potential engagement Documents related to identification information Documents related to financial information for servicing the engagement Information required to comply with our legal obligations
Interactions related to event invitations, updates, or other marketing materials	Name Personal contact details (e.g., personal email address, personal address, telephone number(s)) Company contact details (e.g., company name, position, business email address, business address, telephone number(s)) Communication preferences (e.g., type, frequency, feedback, continuation) Information collected through alumni relationship Information collected through our e-mail systems (e.g., opening emails, clicking links in emails) Other information, such as for purposes of attending an event or for purposes of providing feedback
Interactions with us during the recruitment process	Contact details (e.g., personal, business or educational institution email address, telephone numbers, address) Resumé, including relevant skills and experience Passport, work permit, visa, or other immigration documentation Results of background checks including references, qualifications, and to the extent permitted by law, criminal background checks Application reasons Language capabilities Special requirements, such as, or relating to, a disability / health issue Other personal data provided during the recruitment process

B. Personal data that we may collect through cookies

"Cookies" are small pieces of information that are stored by your browser on your computer's hard-drive for record-keeping purposes.

Bracewell uses cookies on its website to obtain web analytics from third-party vendors. These third parties use cookies to help analyze how users use the website. The information generated by the cookie about your use of the website (including your IP address) will be transferred to and stored by third-party vendors on servers in the United States. These vendors will use this information for the purposes of analyzing your use of the website, creating reports on the website activity, and providing other services relating to the website activity. These vendors may also transfer this information to other third parties where required to do so by law, or where such third parties process the information on the vendor's behalf.

You can refuse the use of cookies by selecting the appropriate settings on your browser, though please note that if you do so, you may not be able to use the full functionality of the Bracewell website.

4. What we do with your information and on what basis

A. Ways we process your personal data

We may process your personal data in one or more of following ways:

1. Collecting your personal data, such as through our website, from conversations, emails, or meetings with us, or from third parties.
2. Recording your personal data, such as through electronic or handwritten notes that we make.
3. Organizing and storing your personal data, such as on our servers, in our management systems, in our electronic HR systems, in our employee's email inbox folders, with cloud-based services, or in hard copy files.
4. Using your personal data, such as to provide our services to you or to your employer, or address any preferences, complaints, or comments that you have.
5. Disclosing your personal data within the firm or to third parties, such as where necessary, appropriate and/or as required by law (see section 5 providing more information on this below).

B. Our purposes for processing your personal data

We may process your personal data for one or more of the following purposes:

1. To process and manage the provision of our services to you or to your employer
2. To create and deliver personalized communications that are relevant to your preferences
3. To provide invitations to events or other sponsored meetings
4. To facilitate the recruitment process
5. To respond to your questions, comments, complaints, or requests
6. To facilitate the recruitment process
7. To comply with our legal obligations

C. Legal basis for processing your personal data

 We may process your personal data on one or more of the following bases:

1. Consent
2. To perform under a contract with you
3. To comply with our legal obligations
4. In pursuit of our legitimate interests

Our legitimate interests include one or more of the following:

1. Supporting client representations, including business communications
2. Complying with our ethical obligations
3. Maintaining and managing our subscription offerings
4. Maintaining and managing our communications with you
5. Expanding our service offerings
6. Growing our business
7. Expanding our professional networks
8. Consideration for future employment

5. DISCLOSURE OF YOUR INFORMATION

We take your privacy seriously and will not share your personal data with others, except in the following circumstances:

1. Service providers – we may disclose your personal data to third-party service providers, such as website hosting, information technology services, payroll services, auditing services, consultancy services, regulatory services, and legal services in other countries.
2. Our affiliated offices – we may disclose your personal data to our other group entities in order to provide you or your employer with tailored services and communications, or in accordance with our business administrative practices.
3. Government Agencies – we may disclosure your personal data to government agencies as required, for example to provide services, at your direction, or at the direction of your employer.
4. To fulfill your option to share our website content with third parties – using the sharing features on our website (to share content with Facebook, LinkedIn, or Twitter, for example).
5. Legal reasons – we may use or disclose your personal data as we deem necessary or appropriate under applicable laws.

International transfers of personal data

Some of our affiliated offices and service providers are located in the United States. Accordingly, please note that we will transfer personal data from our non-US offices to the United States in accordance with data protection law requirements by using standard contractual clauses that have been approved by the European Commission.

6. RETAINING YOUR DATA

We retain your personal data in accordance with our retention policies, and in accordance with applicable laws. The actual retention period for your personal data depends on the nature of our exchanges with you.  We do not collect more personal data than we need to fulfill our purposes stated in this privacy policy.

7. WHAT RIGHTS DO YOU HAVE WITH RESPECT TO YOUR PERSONAL DATA?

If you are a client of Bracewell (UK) LLP or an EU resident, you may have the following rights with respect to the personal data you provide to us, to the extent permitted by applicable data protection laws:

a) To withdraw any consent that you have provided to us to process your personal data.

b) To access or rectify your personal data.

c) To have your personal data erased if it is no longer necessary for the purposes for which it was processed; you have withdrawn your consent to its processing; or you object to its processing and there is no overriding legitimate interest to continue its processing.

d) To have the processing of your personal data restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it.

e) To have your personal data transferred to another company under certain circumstances.

f) To complain to your national data protection regulator if you feel that your personal data has been unlawfully processed.

To make inquiry regarding these rights or to make a request with regard to one of these rights, please contact privacy@bracewell.com. Please be prepared to provide information that will allow us to confirm your identity and indicate the nature of our exchanges with you, e.g., client context, solely marketing context. By providing us this information it will enable us to better respond to your inquiry. 

8. HOW WILL WE PROTECT YOUR PERSONAL DATA?

We have implemented security policies and technical measures to protect the personal data that we collect, consistent with applicable privacy and security laws. These security measures are designed to prevent unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss of your personal data.

We update and test our personal data privacy and security measures on an ongoing basis. We also provide training to our employees on privacy laws and how to comply with them. We ensure that only employees who need to know your personal data to fulfill the purposes of processing that personal data (as described in this privacy policy) have access to it.

9. LINKS TO THIRD-PARTY SITES

Our website may include links to other sites operated by third parties. We are not responsible for information on these sites, nor for services or products offered by them. Use of such sites, including transmitting your personal data to them, is at your own risk. You should check the privacy policies (and other applicable terms and conditions) of these third-party sites.

10. CHANGES

We review our privacy practices on an ongoing basis, and as such we may change this privacy policy from time to time. If such change includes any significant, material changes, we will provide clear notice of the update on the homepage of our website. Please check this policy frequently to ensure that you are familiar with its current content.

This privacy policy was last updated on May 23, 2018.