DECHERT CALIFORNIA NOTICE AT COLLECTION AND PRIVACY NOTICE

This Dechert California Notice at Collection and Privacy Notice (“California Privacy Notice”) supplements the information contained in our Online Privacy Policy. It is delivered on behalf of Dechert LLP (“Dechert”) and our affiliates and governs the personal information we collect from California residents (“you”) on any website on which a link to this California Privacy Notice appears and any personal information we otherwise collect from consumers.

We have adopted this California Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”). Please take the time to read and understand this California Privacy Notice. Please also read our Online Privacy Policy. which includes important information regarding how we collect, use and share your personal information.

Scope

Most of the personal information we collect about California residents is not covered by this California Privacy Notice. The CCPA includes certain exemptions that may apply to our collection and processing of your personal information. It is possible that not all personal information we collect from or about you is fully covered by the CCPA. Therefore, this California Privacy Notice and the California privacy rights set out herein may not apply to you or to all of your personal information. For example:

Personal information that we collect about you in a business-to-business context, including when you are communicating with us as an employee of a business to whom we are providing or receiving a product or service is not covered by this California Privacy Notice.
Personal information we have from individuals in their capacity as California-resident current or former Dechert employees or California-resident Dechert job applicants is not covered by this California Privacy Notice. If you are a California-resident job applicant, please see our CCPA Recruitment Privacy Notice

In addition, publicly available information, de-identified data and aggregate California resident information (as those terms are used in the CCPA) are not personal information for purposes of the CCPA. This California Privacy Notice does not apply to such information.

Notice at Collection

We may collect the following categories of personal information from you:

Identifiers
Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
Geolocation data
Internet or other electronic network activity information
Inferences drawn from other personal information

We may use your personal information for the following purposes:

To present our Website and its contents to you
To fulfill your requests for products or services
To communicate with you
To conduct analytics, better understand how you use our Website and improve our Website and business
To market to you
To protect our rights and meet our legal obligations
As permitted or required by law or as we may notify you

Our Prior Collection, Use and Sharing of Personal Information

The CCPA requires us to give you specific information about the categories of personal information we collect about you, the sources from which we have obtained that information, the purposes for which we collect it and the categories of entities with whom we share it. This table sets out our relevant practices over the last twelve months. Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with our Website. For more information regarding the personal information we collect from you via our Website, please read our Online Privacy Policy.

Category of Personal Information	Categories of Sources From Which Collected	Business or Commercial Purpose for Collecting & Sharing the PI	Categories of Third Parties and Other Entities With Whom We May Share
• Identifiers, such as IP address, mobile device id, cookies and or other online identifiers • Categories in Cal. Civ. Code 1798.80(e), such as IP address, mobile device id, cookies and or other online identifiers • Internet or other electronic network activity information, such as browsing, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement • Geolocation data, such the state or country associated with your IP address • Inferences drawn from this information, such as preferences or other Website visitor characteristics	• Directly from you such as when you visit our Website • From your devices • Via cookies and other tracking technologies	• To present our Website and its contents to you • To fulfill your requests for products or services • To communicate with you • To conduct analytics, better understand how you use our Website and improve our Website and business • To market to you • To protect our rights and meet our legal obligations • As permitted or required by law or as we may notify you	• Our affiliates • Entities that provide marketing services • Our business partners and service providers • Legal authorities as required by law or to protect our rights • Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)

How We Share Personal Information

In the last twelve months, we have disclosed the following categories of personal information for business purposes:

Identifiers
Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
Geolocation data
Internet or other electronic network activity information
Inferences drawn from other personal information

Sales of Personal Information

The CCPA defines the term “sale” very broadly. We do not currently sell your personal information for purposes of the CCPA. In the past twelve months, we have disclosed the following categories of personal information to third parties that provide services to us, such as website analytics services and certain website functionalities. Such disclosures may be considered a “sale” for purposes of the CCPA:

Identifiers
Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
Geolocation data
Internet or other electronic network activity information
Inferences drawn from other personal information

Choices Related to Online Tracking

As set out above, we and third parties collect and use your personal information for online tracking. Please see our Cookie Policy for more information.

If at any time you would like to manage your cookie preferences, please visit the Cookie Preference Center.

Your Rights as a California Resident

As a California resident, you have certain rights in relation to your personal information.

Right to Know
You have the right to know how we have collected, used and shared your personal information over the last twelve months. Specifically, you have the right to know:

The categories of personal information we have collected about you.
The categories of sources from which we have collected your personal information.
The business or commercial purpose for which we collect or sell your personal information.
The categories of third parties with whom we share your personal information.
The categories of personal information that we disclosed for a business purpose and the categories of third parties to whom your personal information was disclosed for a business purpose.
The categories of personal information we have “sold” to third parties and the categories of third parties to whom we have “sold” your personal information.

You have the right to know the specific pieces of personal information we have collected about you over the last twelve months.

Right to Make a Deletion Request

You have the right to request that we delete your personal information. Subject to certain exceptions, we must delete your personal information and direct our service providers to delete your personal information.

Right to Opt-Out of Sales of your Personal Information

You have the right to opt-out of the sale of your personal information.

Right to Non-Discrimination
You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.

How to Exercise Your California Privacy Rights

If you or your authorized agent wishes to exercise your rights to know, access or delete your personal information, please submit a request to us via the California Consumer Request Form, call us at (833) 255-7934 or contact us at privacy@dechert.com.

Verifying Your Requests

We only respond to requests that you make which are “verifiable.” To verify your requests, we may require authentication of you or the Authorized Agent acting on your behalf that is reasonable in light of the nature of the personal information requested.

We may need additional information from you to verify your request. In order to verify your request, we may need to obtain additional information about you to match the information we already have about you. If you provide us with new personal information that we did not already have about you, we will use it solely for the purposes of verifying your request. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly.

We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.

If we cannot verify your request, we will let you know.

Responding To Your Requests

We aim to promptly verify your requests and respond to your requests within 45 days of receipt, but may require up to a total of 90 days to respond to your requests. If we require additional time beyond the initial 45 days and that time is reasonably necessary, we will let you know within the first 45 days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

Unless you tell us that you would like to receive a response via postal mail, we will respond to you via email regarding your requests to know and to access the specific pieces of personal information we have about you. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal information via postal mail rather than email, please let us know when submitting your request(s).

Limitations

The CCPA does not apply in full to all personal information we collect from California residents. As set out in “Scope” above, the CCPA is not fully applicable to much of the personal information we collect from California residents. Therefore, even if you are a California resident and submit a verifiable request, we may not be required to comply with your request.

We are only required to respond to certain requests twice in any twelve-month period. We are not required to provide you access to specific pieces of personal information more than twice in any twelve-month period. Similarly, we are not required to comply with your “requests to know” more than twice in any twelve-month period.

Do Not Track

Dechert relies on a third-party provider in an effort to honor and respond to do not track privacy signals that may be sent by your browser.

Changes to Our California Privacy Notice

This California Privacy Notice may be changed by Dechert or its affiliates at any time and such changes will apply to information we collected from you pursuant to a previous privacy policy. If there are changes to the terms of this privacy policy, documents containing the revised policy on the relevant website will be updated.

How to Contact Us

If you have any questions or concerns about this California Privacy Notice, please contact us at privacy@dechert.com.

This California Privacy Notice was last revised on July 1, 2020.