California Privacy Notice

Updated: Effective March 21, 2022

Baker & Hostetler LLP (“BakerHostetler,” “us,” “we,” or “our”) provides this California Privacy Notice (“Notice”) pursuant to the California Consumer Privacy Act (the “CCPA”). This notice supplements BakerHostetler’s other privacy policies and notices, including our main Privacy Policy. In the event of a conflict between any other BakerHostetler policy, statement, or notice and this Notice, this Notice will prevail as to California consumers and their rights under California law.

1. PERSONAL INFORMATION WE COLLECT & WHY WE COLLECT IT

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

Within the past 12 months, we collected the following categories of Personal Information about California consumers. The specific pieces of Personal Information we collected about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

The chart above reflects the categories of Personal Information required to be disclosed under the CCPA. There may be additional information that we collect that meets the CCPA’s definition of Personal Information but is not reflected by a category, in which case we will treat that information as Personal Information as required by the CCPA.

2. SOURCES OF PERSONAL INFORMATION

We may collect your Personal Information directly from you when you provide us information online, through electronic forms, over the phone, or through paper documents; automatically through our website via cookies and other tracking technologies; from our service providers, vendors and suppliers, affiliates, or other individuals and businesses; from third-party sources, such as data providers; and from public sources of data, such as government databases. More detail on the ways in which we collect Personal Information can be found in our Privacy Policy.

3. DISCLOSURES OF PERSONAL INFORMATION

We do not sell Personal Information. We share Personal Information with our Service Providers for the business purposes listed in the chart above. The categories of Personal Information we share for a business purpose are:

1. Identifiers
2. Personal Records Described in Cal. Civ. Code § 1798.80(e)
3. Protected classification characteristics
4. Commercial Information
5. Internet or other electronic network activity information
6. Geolocation Data
7. Audio, electronic, visual, thermal, olfactory, or similar information
8. Inferences

The categories of persons to which we disclosed this Personal Information include affiliated and related companies, service providers, professional advisors, public authorities/government bodies, and external auditors. More information on how we share Personal Information can be found in our Privacy Policy.

4. CCPA RIGHTS

Under the CCPA, California consumers have certain rights which they may exercise independently or through an authorized agent. Please note that when submitting a request, you may be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will still need to verify your identity directly with us before we can process the request.

To submit a request, use our portal here, or call us at (888) 914-9661, Extension PIN: 530 983.

1. THE RIGHT TO KNOW

If you are a California consumer, you have the right to request more information regarding the following, to the extent applicable:

1. The categories of Personal Information we have collected about you;
2. The categories of sources from which the Personal Information was collected;
3. Our business or commercial purposes for collecting your Personal Information;
4. The categories of third parties with which we shared your Personal Information;
5. The categories of Personal Information that we disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information; and
6. The specific pieces of Personal Information we have collected about you.

You may submit a request for this information as described above. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.

2. THE RIGHT TO OPT OUT OF SALES OF PERSONAL INFORMATION

California consumers have the right to opt out of the sale of their Personal Information.  However, because we do not sell Personal Information, there is no need to submit such a request to us.

3. THE RIGHT TO DELETE

Using the request submission methods outlined above, you may request that we delete your Personal Information that we have collected directly from you and are maintaining. Following receipt of a request to delete, we will need to take steps to verify your identity before action is taken. We will let you know what Personal Information we can delete from our records, and we will direct any of our service providers that may have processed your Personal Information on our behalf to delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct service providers to delete your Personal Information from their records.

4. NON-DISCRIMINATION

You have the right to not receive discriminatory treatment for exercising your CCPA privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.

5. CONTACT US

If you have any questions about this Notice, please contact BakerHostetler by email here, call us at (888) 914-9661 PIN 530 983, or send a letter to BakerHostetler at: One Cleveland Center, 1375 East 9th Street Suite 2100, Cleveland, OH 44114-1794, (Attention: Privacy Inquiry).