Stroock & Stroock & Lavan LLP (“we,” “our,” and “us”) is furnishing this Supplemental Privacy Notice (“Supplemental Notice”) to natural persons residing in the State of California (“you”, “your”), pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). This Supplemental Notice supplements and should be read together with our Privacy Policy. Any terms defined in the CCPA have the same meaning when used in this Supplemental Notice.

This Supplemental Notice is dated and effective January 1, 2020.

The CCPA requires certain disclosures that already are covered in our Privacy Policy. This Supplemental Notice provides additional information required by CCPA, including information about how California residents may exercise your rights under the CCPA.

The CCPA permits natural persons who are California residents to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their Personal Information (if any) in the prior calendar year, as well as the type of Personal Information disclosed to those parties. We do not sell, rent, trade or share Personal Information with third-parties for their own marketing purposes.

We do not sell your data. We only disclose Personal Information to unaffiliated third parties as set forth in this Policy. You have the right to request information from us regarding whether we share certain categories of your Personal Information with third parties for our marketing purposes. To the extent we share your Personal Information in this way, you may request information related to (i) the categories of information we disclosed to third parties for such purpose during the 12 months and (ii) the names and addresses of third parties that received such information.

Categories & Sources of Information

As further described in our Privacy Policy, in order to provide the Services, we have collected the following categories of Personal Information in the past twelve months:

• Identifiers, such as name, postal or electronic address, and government-issued identifiers (e.g., taxpayer identification number);
• Personal information as defined under the California Customer Records statute (California Civil Code § 1798.80(e)) such as contact information, financial information and insurance information;
• Characteristics of protected classifications under California or federal law, such as age, gender, gender or sexual orientation;
• Commercial information, such as records of personal property;
• Biometric data such as fingerprint, image and user behavior characteristics;
• Internet or network activity information, such as browsing history and interactions with our website;
• Geolocation data, such as device location and Internet Protocol (IP) location;
• Audio, electronic or similar information, such as call recordings; and
• Professional or employment-related information, such as education, job title and position and employer information.

We collect the foregoing information directly or indirectly from you and/or your authorized representatives in connection with our provision of Services, through automatic collection from your web browser when you visit our website, from public sources (e.g., courts, secretaries of state, agencies which monitor legal compliance) and from other sources such as third-party vendors (e.g., accounting firms, other law firms).

See “Categories and Sources of Information” in our Privacy Policy to learn more.

Uses of Information

We use Personal Information to provide Services and to accomplish our business and commercial purposes and objectives, including the following:

• To meet the reason you provided the information and to administer and perform the Services;
• To provide, maintain, personalize and develop our website, databases, network, infrastructure, devices, assets and Services;
• To debug, including to identify and repair technical errors that impair intended functionalities;
• To perform security functions, including to detect security breaches, protect against fraud and malicious activities, and take action against wrongdoers;
• To serve and protect the rights, property or safety of our clients, employees, us or others, as necessary or appropriate;
• To perform auditing functions, including legal and regulatory compliance;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets;
• To respond to governmental authorities, including law enforcement requests, and as required by applicable law, court order, or regulations; and
• As described to you when collecting your personal information or subsequently agreed to by you, and as otherwise permitted under the CCPA.

See “How We Use Personal Information” in our Privacy Policy to learn more.

Sharing of Information

We may share Personal Information with certain trusted third parties.  For example, we may share Personal Information with:

• Service providers and vendors to perform functions and provide services, such as website and database hosting and maintenance, data analytics, billing and payment processing, and other activities relating to client relationships, marketing and marketing research, error monitoring, debugging, and information technology and related infrastructure;
• Other third parties to whom you or your authorized agent authorize us to share personal information in connection with our Services; and
• Governmental authorities or other entities as required by law or regulation.

We share personal information to the extent necessary to provide Services and to accomplish our business and commercial purposes and objectives, and we require these third parties to maintain the privacy and security of the Personal Information they access.  We do not sell or rent your personal information to unaffiliated third parties, such as sellers of goods or services, for their own business or commercial purposes.  We may share anonymous or aggregated information with third parties to help deliver products, services and content and for other purposes.

See “How We Share Personal Information” in our Privacy Policy to learn more about the categories of Personal Information we disclose, and the categories of third parties to whom your Personal Information is disclosed.

Your Rights

California residents have the right to:

• Know your Personal Information. The CCPA permits users of our Services who are California residents to request and obtain from us twice a year, free of charge, information related to Personal Information we have collected in the 12 months preceding the request, including the categories of Personal Information collected, the categories of sources from which the Personal Information is collected, the specific pieces of Personal Information we have collected, the business or commercial purpose for collecting Personal Information, the categories of Personal Information that we disclose to third parties and the categories of third parties with whom we share your Personal Information. See further instructions for receiving your Personal Information, below.
• Delete your Personal Information. You may request that we delete the Personal Information that we have collected from your use of the Services. We will delete your information unless it is necessary for purposes permitted by CCPA. See further instructions for deleting your Personal Information, below.
• Opt-Out. The CCPA gives you certain rights to opt-out of the sale of any of your Personal Information. Since we never sell, rent or trade your Personal Information, you need take no further option to opt-out from the sale of your Personal Information.
• Consent to new uses. Before we use Personal Information for any purpose not previously disclosed to you, we will notify you of this new use and obtain explicit consent from you to use it for this purpose.
• Non-discrimination. If you choose to exercise any of these rights, we will not deny services to you or provide different quality of services, unless that difference is reasonably related to the value provided by your data.
• Authorize an Agent. You may designate an agent to make a request under the CCPA on your behalf. To do so, please provide the agent a written letter appointing the agent, acknowledged before a notary public. The agent must furnish a copy of the appointing letter to us when taking action under the CCPA on your behalf. You may also point an agent using a power of attorney pursuant to California Probate Code, Sections 4000 to 4465.

To request information about your own Personal Information, or to request that we delete your Personal Information, please contact us at the contact information shown below. In accordance with CCPA requirements, your request must (1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, and (2) describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identify or authority to make the request and confirm the requested personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify the requester’s identity or authority to make the request.

Stroock & Stroock & Lavan LLP
Attn: CCPA Requests
2029 Century Park East
Los Angeles, CA 90067-3086
Call toll free at:  1-833-391-0342
Submit online requests via email to: ccpa_requests@stroock.com