This is the Privacy Policy for Gordon-Creed, Kelley, Holl, & Sugerman (GKHS).

1. Scope

This Privacy Policy applies to the personal information we collect related to our:

• websites, including www.gkhs.com and any other websites that display this Privacy Policy for GKHS, and the services available through our websites (together, our “Sites”);
• business contacts, communications and other online and offline business interactions; and
• legal and professional services that we provide, including pitches and proposals that we respond to (“Client Services”).

Collectively, we refer to the above as our “Services.” Additional or different privacy notices may apply to certain of our Services. If a different or supplemental privacy notice applies, this will be disclosed to you.

California Consumer Privacy Act. If you are a California resident, please review Section 7. Additional privacy information for California residents below, for important information about how we collect, use and disclose personal information about California residents and your rights under the California Consumer Privacy Act.

Not in scope. This Privacy Policy does not apply to the personal information that we collect about employees, contractors and other personnel related to their working relationship with us, or the personal information that we collect about applicants and candidates for a position with GKHS. We may also collect, generate, use and disclose aggregate, anonymous, and other non-identifiable data related to our Services, which is not personal information subject to this Privacy Policy.

2. Information we collect

We may collect information directly, as well as from third parties or automatically related to the use of our Sites and Services.

• Information collected directly
  We may collect personal information about you directly from you. For example, personal information may be collected when you fill out a ‘Contact Us’ form, hire us as counsel for our Services, or otherwise provide us personal information through the Sites and Services. Generally, the information we collect includes your:
  • Name, company name and title/position.
  • Email address, phone number, mailing address and contact details.
  • Contact preferences and interests.
  • Information provided in conjunction with our Client Services.
  • Other information related to your request or inquiry, or that you provide when you communicate, engage or otherwise interact with us or the Services.
• Automatically-collected information
  We may use cookies, log files, pixel tags, local storage objects and other tracking technologies to automatically collect information including personal information when users access or use our Sites, mobile applications and other online services, such as an IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information.
• Information received from third parties and other sources
  We may collect or receive information about individuals from service providers, and other third parties, such as our clients, representatives and professional advisers, content providers, government authorities, public sources and records, and other third parties (such as ISPs, platforms, operating systems, and social media platforms).

3. Purposes Of Use and Processing. Generally, we use, disclose and otherwise process the personal information we collect in order to respond to your request or inquiry, as directed or authorized by you, and for the following purposes:

• Providing support and services and performing Client Services
  To provide our Services, communicate with you about Services, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for other service and support purposes.
• Responding to requests
  To respond to your inquiries, fulfill your orders and requests, and otherwise consider or process your request.
• Protecting rights and preventing fraud and misuse
  To protect the Sites, Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of us or any person or third party, or violations of our Terms of Use or other agreements; and to respond to actual or potential legal claims against us.
• Complying with legal and ethical obligations and legal process
  In order to respond to legal process (eg, court orders, subpoenas or warrants) or regulator investigations and inquiries, or where otherwise required by law or our legal, regulatory or ethical obligations.
• Supporting our business operations and business transactions
  Where necessary, for the administration of our general business, accounting, recordkeeping, audit, compliance and legal functions, as well as to consider and implement various business transactions, such as mergers, acquisitions, and reorganizations.

4. Disclosure of personal information

We may disclose personal information to the following categories of third parties:

• Third party service providers and vendors that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services.
• Our professional advisers, such as lawyers and accountants.
• Regulators, tax authorities and/or corporate registries.
• Government agencies, judicial and quasi-judicial bodies, and other public bodies.
• Agents and advisors, such as professional indemnity insurers.

In addition, we may disclose personal information to other third parties as directed or authorized by the relevant data subject, as well as under the following circumstances:

• Comply with law, legal process and ethical obligations
  To comply with the law and our ethical obligations, respond to legal process or regulator investigations and inquiries, or where otherwise required by law or our ethical obligations. For example, we may disclose information in response to subpoenas, court orders and/or other lawful requests by regulators and/or law enforcement, including responding to national security or law enforcement disclosure requirements.

• Performance of Client Services
  Subject to the terms of our engagement, we may disclose information to others where required or necessary for our provision of Client Services. For example, to our clients, with respect to the relevant legal services we provide to them, to local counsel and other firms as relevant and necessary to a particular matter, or to respond to other parties in legal matters for which we have been engaged as legal counsel.

• Protecting rights and preventing fraud and misuse
  Where we believe it necessary to respond to claims asserted against us, enforce or administer our agreements and terms, or for fraud prevention, risk assessment and investigation, and to protect and defend the rights, property or safety of GKHS, our clients and customers, or others.

We may also share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

5. Our commitment to security. We employ security measures to prevent unauthorized access to information that we collect online. However, we cannot guarantee the security of your personal information.

6. Revisions to our Privacy Policy. We reserve the right to revise this Policy or any part of it from time to time. Please review the Policy periodically for changes. If we make material changes, we will endeavor to provide notice ahead of such changes, such as by email.

7. Additional Privacy Information for California Residents. In this section, we provide additional information to California residents regarding their privacy rights and our collection, use and disclosure of their personal information, as required by the California Consumer Privacy Act (“CCPA”). This section does not apply to publicly available information or other personal information that is exempt from or not subject to the CCPA.

1. Categories of personal information that we collect and disclose

While our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we collect and have collected in the prior twelve (12) months about California residents, as well as the categories of third parties to whom we may disclose this information for a business purpose.

We only gain this information when you directly disclose it to us or through the process of providing Services to you.

No information shall be disclosed to third-parties without gaining your prior approval. Third parties that may be disclosed to include advisors and agents, judicial and quasi-judicial bodies, regulatory agencies and government entities, legal support firms, and parties and related parties in legal matters.