Privacy Notice for California Residents

Effective Date: January 28, 2020

For residents of the State of California ("consumers or "you"), this Privacy Notice for California Residents supplements the information contained in the Privacy Policy available on the website from which you accessed this Notice (the "Site"), and in any other privacy notice we provided to you at the point where we collect your personal information. California’s Consumer Privacy Act of 2018 (the "CCPA") requires that we tell you about the categories of personal information collected by Blank Rome LLP ("Blank Rome," "we", "us" or "our"), the sources from which we collect personal information, the categories of your personal information that we share, and the kinds of third parties with whom we share your personal information. We have set out that information in this Notice to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this Notice.

Please note that this Notice does not apply to personal information that we collect from employees or job applicants, or from owners, directors, officers, or contractors of Blank Rome in the course of our provision or receipt of business-related services.

Data Collection Notice

Blank Rome collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household ("personal information"). In particular, we collect the categories of personal information specified bellow. Blank Rome may use, share, or disclose these categories of personal information for one or more of the indicated business or commercial purposes.

  Categories Description Purpose(s)
A Identifiers A real name, alias/nickname, postal address, Internet Protocol address, email address, or other similar identifiers.
  • "To fulfill or meet the reason you provided the information, such as responding to your inquiry, processing your request, verifying your information and monitoring and improving our responses.
  • To deliver content and product and service offerings relevant to your interests (including via email)
  • To help maintain the safety, security, and integrity of our website, products and services, and properties.
  • To manage and operate our web properties, fulfill our legal obligations, and develop our website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information.
  • To evaluate or conduct any sale or transfer of some or all of Blank Rome’s assets, in which personal information held by Blank Rome about consumers is among the assets transferred."
B Categories listed in the California Customer Records statute A name, home or business address, home or business telephone number, education, employment.
C Protected classification characteristics under California or federal law. Age (40 years or older), marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).
D Internet or similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
E Professional or employment-related information Current or past job history.

California Rights and Choices

Subject to certain restrictions, the CCPA gives California residents certain rights to request access to personal information that Blank Rome has about you, to request deletion of personal information that we collect and maintain, and to opt-out of the sale of personal information about you. This section describes how you can exercise those rights and our process for handling your requests.

Right to Know and Request Access to Your Personal Information

California residents have the right to know and request a copy of the following: (1) the categories of personal information we collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting or, if applicable, selling, the personal information; (4) the categories of third parties with whom we share personal information; and (5) the specific pieces of personal information we have collected about you.

To submit a request, please visit our CCPA data online request portal or call 1-833-BROPTOUT (833-267-7868).

In order to verify you are the person about whom we collected personal information, we will verify your identity by matching at least two pieces of personal information provided by you with personal information maintained by Blank Rome that we have determined to be reliable.

If your request involves receiving specific pieces of personal information (rather than categories of personal information), we must first verify your identity by matching at least three pieces of personal information provided by you with personal information maintained by Blank Rome that we have determined to be reliable. Then, you must provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

We cannot respond to your request to provide any personal information if we cannot verify your identity using the information provided.

In the preceding 12 months, Blank Rome has not sold consumer personal information to third parties. We do not sell the personal information of consumers we actually know are less than 16 years of age without affirmative authorization.

The chart below provides information regarding the categories of personal information Blank Rome collected, used, disclosed, and sold in the past 12 months.

  Categories Collected Source of Collection Third Parties with Whom Shared For A Business Purpose Sold Purpose(s)
A Identifiers (including, without limitation, a real name, alias/nickname, postal address, Internet Protocol address, email address, or other similar identifiers)
  • You (directly)
  • Third parties
  • Public records
  • Referral sources
  • Service Providers
  • Package, mail and delivery service providers
  • As directed by you
No
  • To fulfill or meet the reason you provided the information, such as responding to your inquiry, processing your request, verifying your information and monitoring and improving our responses.
  • To deliver content and product and service offerings relevant to your interests (including via email)
  • To help maintain the safety, security, and integrity of our website, products and services, and properties.
  • To manage and operate our web properties, fulfill our legal obligations, and develop our website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information.
B Categories listed in Cal. Civ. Code § 1798.80(e) (including, without limitation, a name, home or business address, home or business telephone number, education, employment)
  • You (directly)
  • Third parties
  • Public records
  • Referral sources
  • Service Providers
  • Package, mail and delivery service providers
  • As directed by you
No
C Protected classification characteristics under California or federal law (including, without limitation, age (40 years or older), marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions))
  • You (directly)
  • Third parties
  • Public records
  • Service providers
  • Third parties
  • As directed by you
No
D Commercial information (including, without limitation, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
  • Not collected
  • Not shared
No
E Internet or similar network activity (including, without limitation, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement)"
  • You (indirectly)
  • Service providers
  • Third parties
  • Service providers
  • As directed by you
No
F Sensory data (including, without limitation, audio, electronic, visual, thermal, olfactory, or similar information)
  • Not collected
  • Not collected
No
G Professional or employment-related information (including, without limitation, Current or past job history)
  • You (directly)
  • Third parties
  • Public records
  • Service providers
  • As directed by you
No
H Inferences drawn from other personal information (including, without limitation, to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)
  • Not collected
  • Not shared
No

Right to Request Deletion of Personal Information

You have the right to request that Blank Rome delete personal information that we collected from you and retained, subject to certain exceptions.

To submit a request, visit our CCPA data online request portal or call 1-833-BROPTOUT (833-267-7868). In order to process your request, we will verify your identity by matching at least two pieces of personal information provided by you with personal information maintained by Blank Rome that we have determined to be reliable. If your request involves sensitive personal information, we must first verify your identity by matching at least three pieces of personal information provided by you with personal information maintained by Blank Rome that we have determined to be reliable. Then, you must provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

We cannot respond to your request to provide any personal information if we cannot verify your identity using the information provided.

Request Processing and Timing

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Any disclosures we provide in response to data access and/or data portability requests will only cover the 12-month period preceding the receipt of your request. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, which in most cases will involve Adobe® PDF and comma delineated data files. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

No Sale of Personal Information

Blank Rome does not sell your Personal Information.

Right to Non-Discrimination for the Exercise of Privacy Rights

We will not discriminate against you for exercising any of your CCPA rights. This means that, unless permitted by the CCPA, your exercise of these rights will not result in Blank Rome: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) providing you a different level or quality of goods or services; or (4) suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Designating an Authorized Agent

You may use an authorized agent to submit a request to opt-out of the sale of personal information on your behalf if you provide the authorized agent written permission to do so.

If you use an authorized agent to submit a request for additional disclosures described in Section II(a) or a request for deletion described in Section II(b), he or she must provide their name, email address, phone number, and written permission from you that includes your contact information. We will contact you using the information provided and verify your identity directly with us. We cannot respond to your request to provide additional disclosures or delete any personal information if we cannot verify your identity and the authorized agent’s authority to make the request on your behalf. Written permission is not required if the agent provides proof of power of attorney pursuant to Probate Code sections 4000 to 4465, or you are submitting the request on behalf of your minor child.

Contact for More Information

If you have any questions or concerns about our privacy policies and practices, please do not hesitate to contact us

Phone: 1-833-BROPTOUT (833-267-7868)

Website: www.blankrome.com

Email: privacyoffice@blankrome.com

Postal Address:
Blank Rome
Attn: Privacy Office
130 North 18th Street, One Logan Square, Philadelphia, PA 19103

Other California Privacy Rights

California’s "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacyoffice@blankrome.com or call 1-833-BROPTOUT (833-267-7868).

Changes to Our Privacy Notice

This privacy notice was last updated on December 31, 2019. Blank Rome reserves the right to amend this privacy notice at its discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date.