Policy Effective Date: January 1, 2023
Updated to include (1) the requirements of the California Privacy Rights Act (CPRA) and (2) requirements to comply with Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), its Regulations (RLFPDPPP), and other applicable privacy laws of Mexico.
- Communications Regarding Our Legal Services
- Information Security
- Privacy Notices
- Information We Collect
- How We Use Your Information
- How We Share Your Information
- Where Your Personal Information is Stored
- How Long We Keep Your Personal Information
- Canada, European Union, and United Kingdom Privacy Rights
- Social Media Use Awareness
- Privacy Notice for California Consumers
- Privacy Notice for Mexican Data Subjects
Snell & Wilmer (firm) is a U.S. law firm based in Phoenix, Arizona. We maintain twelve offices in Arizona, California, Colorado, Nevada, Oregon, Utah, Washington, D.C., and in Mexico. We also operate from locations in Idaho, New Mexico, Texas, and Washington State. We may collect personal information from any of our offices or locations.
Our processing of personal information, such as your name, address, e-mail address, or telephone number, will be undertaken consistent with the requirements of applicable privacy laws, including, but not limited to, the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the EU General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA).
Communications Regarding Our Legal Services
Please note that any communications that you may have with us do not establish an attorney-client relationship. Any information sent to Snell & Wilmer before establishing an attorney-client relationship will not be held in confidence and may be used for the benefit of the firm's other clients or future clients. Accordingly, unless and until we formally establish an attorney-client relationship, do NOT send, or otherwise communicate to us any information you would want to be maintained in confidence, whether through this website, through any email address posted on this website, or otherwise.
Any information you send to us electronically, while using our website or our legal services or otherwise interacting with us, may not be secure during its transmission. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you transmit to us through any means is sent at your own risk.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or with your device ("Personal Information").
Information We Collect Directly
Sources of Personal Information We Collect Directly
We may collect information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent:
- In relation to a business association between you and Snell & Wilmer or one or more of its personnel.
- From third parties involved in legal proceedings in which you are named or otherwise associated.
- From legal and regulatory agencies and entities.
- From conversations, mail, email, faxes, voicemail, and texts sent to our personnel.
- From social media services.
- From the device(s) you use as a visitor to our website.
- From the device(s) you use to connect to our networks.
- Via our website, swlaw.com.
- Through your subscription to one or more of our publications, newsletters, blogs, or other informational services or materials.
- By your acceptance of an invitation to and/or attendance of a firm event.
- By feedback that you have provided to us regarding a firm event or publication.
For current or prospective personnel, we may collect Personal Information in relation to your employment or prospective employment with the firm:
- Through your submission of a resumé, job, or fellowship application.
- Through the recruitment or application process (such as from recruiters engaged by the firm).
- From our background check, credit bureau, and drug testing service providers.
- Through our new hire intake process (such as the forms related to your employment with us).
- In relation to an employment relationship between you and Snell & Wilmer (such as for benefits administration).
- Through documentation of your activity on our networks, systems, applications, and databases and analysis of reports and activity logs.
Types of Personal Information We Collect Directly
We receive personal information as described to you at the point of collection, pursuant to your consent, and/or when you voluntarily provide us with personal information, including: (1) individual information (such as your email address and phone number); (2) company information (such as your company’s address); and (3) other identifying information that you voluntarily choose to provide to us, including without limitation unique identifiers such as passwords, and personal information in messages you send to us. We may also collect additional information, which may be personal information, as otherwise described to you at the point of collection or pursuant to your consent.
Here are some additional examples of Personal Information we collect or may collect directly:
- Full name, alias.
- Postal address.
- Home and/or mobile phone number.
- Personal email address.
- Name, phone number, and/or email address of your named beneficiary and emergency contacts.
- Financial information (such as Billing and payment information on your account).
- Driver’s license number or state ID card number.
- Name of your business or your employer.
- Your job title.
- Business email address.
- Business address.
- Business and/or mobile phone number.
- Languages spoken.
- Health or disability specifics.
- Passport identifiers.
- Work permit, visa or other immigration or citizenship document identifiers
- Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements to our personnel).
- Resumés and job applications.
- Reasons for applying for employment with the firm.
- Information provided by the referrals that you have provided to us for employment consideration.
- Criminal or credit history.
- Name of spouse or partner.
- Your preferences for communications, diet (for meals served at firm events), and other such preferences
- Name, phone number and/or email address of your named beneficiary and emergency contacts.
- Information available to us on Snell & Wilmer’s own social media accounts or on social media sites or services accessible to the public.
- Information related to the client engagement process.
- Login ID and password provided for your access to one of our extranets as well as access and activity logs detailing your use of our extranets, where applicable.
- Your actions on our networks, systems, applications, and databases.
- Personal information as it appears within our application for our Fellowship for Advancement and Resources (FAR) program as it appears on our website, swlaw.com.
- Any other personal information required to comply with our legal duties as a law firm and as an employer.
- Sources of Personal Information We Collect Directly
Information We Collect Indirectly When You Use Our Site
In order to access and use certain areas or features of our website, you consent to our collection and use of certain information about your use of swlaw.com through the use of tracking technologies or by other passive means. Your consent to our access and use of this “passively collected” information may include, but is not limited to, the internet protocol (IP) address used, the length of time spent on our site and the pages you looked at on swlaw.com, the type of device and/or internet browser you have, the frequency of your visits to our site, and other relevant statistics (collectively, “Traffic Data”).
We collect information (including personal information and Traffic Data) when you use and interact with us, and in some cases from third-party sources. Such means of collection may include:
- When you access, use, or contact us through our website or from our personnel.
- When you voluntarily provide information to us.
- If you use a location-enabled browser, we may receive information about your location and device.
- Through cookies, web beacons, analytics services, and other tracking technologies (collectively, “Tracking Tools”).
For more information on cookies, including how to control your cookie settings and preferences, visit https://allaboutcookies.org. You can also manage cookies in your web browser (e.g., Edge, Explorer, Chrome, Safari). If you choose to change cookie settings, you may find that certain functions or features of our website may not work as intended.
“Web Beacons” (aka clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our website. The information collected by web beacons allows us to analyze how many people are using swlaw.com, what pages or services they are using, and for what purpose.
Web Service Analytics
We use third-party analytics services in connection with our website, including, for example, to register mouse clicks, mouse movements, scrolling activity, and text typed into swlaw.com. We use the information collected from these services to help make our website easier to use and as otherwise set forth in the section entitled “How We Use Your Information.” These analytics services generally do not collect personal information unless you voluntarily provide it.
Mobile Device Identifiers
As with other Tracking Tools, mobile device identifiers help Snell & Wilmer learn more about our visitors’ demographics and Internet behaviors in order to personalize and improve the services we provide on our website. Mobile device identifiers are stored on mobile devices that may track activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of personal information (such as media access control, IP address, and relative location) and Traffic Data.
We do not track your online activity across other websites or engage in cross-context behavioral advertising.
Opting Out of Cookies and Mobile Device Identifiers
If we process cookies based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any point in time by contacting us at PrivacyOfficer@swlaw.com. Please note, if you exercise this right, you may have to provide your consent on a case-by-case basis to enable you to utilize some or all of the functions of our website.
You may be able to reject cookies and/or mobile device identifiers by activating the appropriate setting on your browser or device. Although you are not required to accept firm cookies or mobile device identifiers, if you choose to block or reject them, you may not have access to all features available within swlaw.com.
“Do Not Track” (DNT) and Universal Opt-Out Preference Signals
Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to web services that a visitor does not want to have their online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many web service operators, including Snell & Wilmer, do not proactively respond to DNT signals. For more information about DNT signals, visit https://allaboutdnt.com.
New standards are being developed for a Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC), which allow users with GPC-enabled browsers and devices to send a signal that will communicate the user’s request to opt-out of sales of their personal information and to opt-out of certain sharing of their personal information. The CPRA and other laws allow for the acceptance of Opt-Out Preference Signals such as the GPC, as an option for individuals to transmit an Opt-Out of selling/sharing personal information. If we detect and recognize such a signal from your device or browser, we will honor it.
How We Use Your Information
We do not engage in automated decision making. We may use information (including information that has been de-identified and/or aggregated) to understand who uses our website and how we can deliver a better user experience. We use information, including personal information, to provide the legal and other services, improve or develop new services, and to advertise our services. Specifically, such use may include:
- Providing you with the products, services, and information you request.
- Corresponding with you.
- Providing, maintaining, administering, or expanding our services, performing business analyses, and for other internal purposes.
- Fulfilling our legal obligations, such as preventing, detecting, and investigating security incidents, fraud, and potentially illegal or prohibited activities.
How We Share Your Information
In certain circumstances, and in order to provide you with Snell & Wilmer services, we may share certain information about you.
- We may disclose your personal information to legal authorities as a result of legal requests such as subpoenas, court orders, or law enforcement demands) if we believe in good faith that the law requires it, or if we believe that it is necessary to protect our legal interests. We may also report personal information as may be required by law in the event of a suspected or actual violation of applicable laws or regulations.
- We may share your personal information and/or Traffic Data with our partners who perform operational services for us (such as website hosting, information security and web service analytics) or to analyze device activities (such as how often pages on our site are accessed) to improve the services we offer. These partners are required to process your personal information as we have described within our contract with them (or as otherwise described in writing to them) and in compliance with applicable law.
Should you choose to provide us with your resumé or submit a job application for employment consideration with the firm, we will use personal information in those documents for the purpose of evaluating your qualifications for employment. We may share the personal information you have provided to us in these documents with:
- Attorneys or firm personnel who have input to the open position.
- Firm personnel who perform or assist in the gathering of your personal information.
- Our background check service provider.
- References supplied by you.
- Recruiters or employment agencies engaged by the firm.
- We may transfer your personal information to another company in connection with a proposed merger, sale, acquisition, or other change of ownership or control by or of Snell & Wilmer (whether in whole or in part). We will make reasonable efforts to notify you before your information becomes subject to different privacy practices.
Where Your Personal Information is Stored
We store the Personal Information which we collect on encrypted servers and computers located in the United States where data protection and privacy regulations may differ from those in other parts of the world.
How Long We Keep Your Personal Information
If you have provided us personal information via our website, we will retain it while we have an ongoing business relationship with you. We audit our mailing lists regularly to remove contacts with whom we do not have an active business relationship. If you do not want to receive email from us, please “unsubscribe” through the link that is included in our emails. If you do not want to receive mailings, do not check the box to receive such mailings when you give us your personal information, or follow the directions to remove your name from our mailing list.
If you have submitted a resumé or application for employment consideration, we will retain it as part of your personnel file if you are hired. If you are not hired for the position for which you originally applied, we may keep your resumé or job application on file for consideration for possible future openings unless you notify us to delete it. We delete applicant resumés and job applications on file that are dated beyond the period specified in our internal file retention and disposal policy and according to the applicable legislation. If you wish to remove your resumé or application from future consideration, please email PrivacyOfficer@swlaw.com or call us toll-free at 1.800.949.0225.
For our clients and for individuals named within a legal matter, we may retain for a period of time, some, or all of your personal information for legal, ethical, or business reasons.
Canada, European Union, and United Kingdom Privacy Rights
If our processing of your personal information is subject to GDPR, UKGDPR, and/or PIPEDA, and unless subject to an exemption, you may have the following rights with respect to your personal information:
- To request a copy of the personal information we hold about you and where possible, to transmit that data directly to another data controller.
- To request we correct any personal information about you.
- To request your personal information be erased when no longer necessary for us to retain such data.
- To withdraw your consent to the processing of your personal information.
- To request a copy of the personal information we hold about you.
- Where there is a dispute in relation to the accuracy or processing of your personal information, to request a restriction be placed on further processing.
- To object to the processing of personal information (where applicable).
- To lodge a complaint with a data supervisory authority.
We will need to verify your identity to process any requests described in this Section and may deny your request if we are unable to verify your identity. Government or other identification may be required.
If you are a resident of the European Economic Area (EEA), when we process your personal information, we will only do so in the following situations:
- We need to use your information to perform our responsibilities under our agreement with you.
- We have a legitimate interest in processing your personal information. For example, we may process your personal information to send you marketing communications, to communicate with you about the Client Services, and to provide and improve the Client Services.
- We have your consent to do so.
If your personal data is subject to GDPR or UK GDPR, we will transfer personal data from the EEA to a location outside the EEA only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.
Social Media Use Awareness
For your convenience, our website contains links to other websites whose information and privacy practices are probably different than ours. If you choose to use these links, you will leave our website, and will then be subject to the privacy and information practices of those websites. We do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you choose to access any of the other websites listed on our website, you should understand that you do so at your own risk.
We reserve the right to remove comments or postings from any of our social media accounts which we find to be offensive or illegal, unrelated to the intended subject matter or promoting the services or products of other businesses or entities.
Our website is not targeted to children under the age of 16. We do not knowingly collect personal information from any child visiting our website. If we become aware that such data has been collected, we will delete it.
Personal information from children under the age of 16 is generally obtained through parental consent. A child’s parent or guardian may also request that the personal information of their child be deleted from our records by emailing us at PrivacyOfficer@swlaw.com or calling us toll-free at 1.800.949.0225. Information that you provide to us on behalf of a minor child will be treated as personal information. By providing personal information on behalf of another person, regardless of age, you represent and warrant that you have authority to do so.
For individuals under the age of 18 or parents or guardians of individuals living in Mexico, please see the Child Consent section of our Privacy Notice for Mexican Data Subjects appended to this Policy.
Privacy Notice for California Consumers
Notice Effective Date: January 1, 2023
Information We Collect
Snell & Wilmer collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device ("Personal Information"). Any terms defined in the CCPA or CPRA have the same meaning when used in this notice.
In particular, we have collected and disclosed (or may have collected and disclosed) for a business purpose the following categories of Personal Information about California residents within the last twelve (12) months:
|Personal Information Category||Types of Personal Information||Collected?||Categories of Recipients|
|Identifiers||Name, alias, postal address, unique personal identifiers, online identifiers, Internet Protocol (IP) address, email address, account name, Social Security number, driver's license number, passport number.||Yes||Authorized firm HR and benefits personnel, third-party service providers, state and/or federal agencies as required by law, parties involved in legal matters.|
|Personal Information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, beneficiaries, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.||Yes||Authorized firm HR and benefits personnel, third party service providers, state and/or federal agencies as required by law, parties involved in legal matters.|
|Protected Information under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), proof of eligibility to work.||Yes||Authorized firm HR and benefits personnel, third party service providers, state and/or federal agencies as required by law, parties involved in legal matters.|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||Authorized firm marketing personnel, parties involved in legal matters.|
|Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||Yes||Parties involved in legal matters.|
|Internet or other similar network activity||Browsing history, search history, information on a Consumer's interaction with a website, application, or advertisement.||Yes||Third-party service providers, parties involved in legal matters.|
|Geolocation data||Physical location or movements.||Yes||Parties involved in legal matters.|
|Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||Yes||Parties involved in legal matters.|
|Professional or employment-related information||Current or past job history, referral sources provided by you, or performance evaluations.||Yes||Authorized firm HR personnel, third-party service providers, parties involved in legal matters.|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||Yes||Authorized firm HR personnel, third-party service providers, parties involved in legal matters.|
|Inferences drawn from other Personal Information.||Profiles reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes||Authorized firm HR personnel, third-party service providers, parties involved in legal matters.|
Personal Information Exemptions
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated Consumer information.
- Information excluded from the scope of the CCPA or CPRA, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Your Rights and Choices
If you are a California resident you may have the following rights under the CCPA/CPRA in relation to Personal Information we have collected about you, to the extent required by the CCPA/CPRA and subject to verification:
- The specific pieces of your Personal Information collected.
- The categories of your Personal Information collected.
- The categories of sources from whom your Personal Information is collected.
- The purpose for collecting your Personal Information.
- The categories of third parties with whom we have shared your Personal Information.
- Right to Delete:
- The right to request that we delete certain Personal Information we have about you.
- Freedom from Discrimination:
- You have the right to be free from unlawful discrimination for exercising any of your privacy rights.
- Right to Correct:
- You have the right to request that we correct inaccurate Personal Information regarding the information you provide us.
- Right to Restrict the Use of Sensitive Personal Information:
- You have the right to restrict the use of your sensitive Personal Information.
- Right to Access Information on Automated Decision-Making:
- Snell & Wilmer does use automated decision-making tools or methods.
Do Not Sell or Share My Personal Information, Opting OutWe do not sell your Personal Information to anyone.
Limit the Use of My Sensitive Personal Information
The CPRA gives you the right to restrict the use of your Sensitive Personal Information. Sensitive Personal Information is Personal Information that reveals a consumer’s:
- Government ID - Social Security, driver’s license, state identification card, or passport number.
- Finances - account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
- Geolocation - precise geolocation.
- Race, religion, and union membership - racial or ethnic origin, religious or philosophical beliefs, or union membership.
- Communications - private communications unless Snell & Wilmer is the intended recipient of the communication.
- Genetic Data
- Biometrics - biometric information for the purpose of uniquely identifying a consumer.
- Health - Personal Information collected and analyzed concerning a consumer’s health.
- Sexual orientation - Personal Information collected and analyzed concerning a consumer’s sex life, sexual orientation, or preference.
Purposes for Collection, Use, and Sharing
- Legal compliance and auditing related to our interactions with you.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and exercising our related rights.
- Providing and improving services as provided by us or by our service provider(s).
- Internal operations.
- Other one-time or short-term uses.
Additionally, for Snell & Wilmer Personnel, we have or may have disclosed Personal Information for the following purposes:
- To create, maintain, customize, and secure your personnel file.
- To administer payroll and other payment information.
- To set up employment benefits, including but not limited to, health insurance, dental insurance, vision insurance, and 401K plan.
- To provide some third-party service providers information that they may need to set up and administer accounts on your behalf (and by your permission).
- To provide you with support and to respond to your employment inquiries, including to investigate and address your preferences and exercise your rights regarding the handling of your Personal Information.
- To help maintain the safety, security, and integrity of Our internal services and databases and other technology assets, and business.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the firm’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the firm about Our Personnel is among the assets transferred.
As a prospective employer, Snell & Wilmer limits access to the Personal information of professional talent and job applicants to:
- Attorneys or other firm personnel who have input to the open position.
- Firm personnel who perform or assist in the gathering of your Personal Information.
- Our background check service provider.
- Recruiters engaged by the firm.
We will not collect additional categories of Personal Information or use the Personal Information We have collected for materially different, unrelated, or incompatible purposes without providing you notice.
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request, we will determine whether any legal exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers for a variety of reasons.
Exercising Your Access, Data Portability, Opt Out, and Deletion Rights
Only you or your representative that you authorize to act on your behalf may make a verifiable Consumer request related to your Personal Information. You may also make a verifiable Consumer request on behalf of your minor child.
You may only make a verifiable Consumer request for access or data portability twice within a 12-month period.
We ask that you provide us with information so that we may reasonably verify that you are the person about whom we have collected Personal Information or are an authorized representative of that person and to describe your request with enough detail for us to understand, evaluate, and respond to it. We may ask if the following (or similar) questions:
- Are you currently a resident of California or were you a resident of California within the past 12 months?
Have you or the business that you own ever been a firm client? If so,
- Who are or were the attorney(s) assisting you?
- What is (or was) the approximate timeframe that we assisted you?
- Have you been employed by a business located in California in the past 12 months that is or has been a firm client?
- Have you ever been employed by Snell & Wilmer?
- Have you attended firm events either in person or remotely or subscribed to firm newsletters and other media via our website?
To maintain the confidentiality of the Personal Information we may have collected:
- We cannot provide you with Personal Information if we cannot reasonably verify your identity or authority to make the request and confirm the Personal Information relates to you or to the California Consumer who you represent.
- We will use only the Personal Information you or your representative provide within your verifiable Consumer request to verify your identity or your authority to make the request.
All requests to delete Personal Information may be subject to our internal information retention policies and/or to any applicable legal requirements.
Response Timing and Format
We will both acknowledge receipt of your initial request and respond to you with the results of our research into your verifiable Consumer request within the timeframe allowances specified within the CCPA/CPRA.
Any response we provide will only cover the 12-month period preceding the receipt of your verifiable Consumer request and may state reasons as to why we cannot comply with your request.
We will use a format to provide your Personal Information that is readily useable and should allow you to transmit the information successfully to another entity.
Changes to Our Privacy Notice
Snell & Wilmer reserves the right to amend this Privacy Notice for California Consumers at our discretion and at any time. When we make substantive changes to this Privacy Notice, we will post a summary at the top of the first page of this Notice and update the Notice effective date.
We will not discriminate against you for exercising any of your rights specified under the CCPA or CPRA.
Privacy Notice for Mexican Data Subjects
Notice Effective Date: August 31, 2022
While this Addendum supplements and addresses certain issues to personal data protection under Mexican law, this Addendum is not meant to be complete and/or exhaustive. Accordingly, to the extent that the personal data protection laws in Mexico differ from the personal data protection laws of the applicable jurisdiction, the personal data protections laws in Mexico shall prevail but only for Mexican Data Subjects.
For the purposes of the following clauses, the capitalized terms have the following meanings:
- “Personal Data” means any information relating to any identified or identifiable individual;
- “Data Subject” means the individual to whom Personal Data relates; and
- “Sensitive Personal Data” means Personal Data which refers to the most intimate areas of a Data Subject's life, or information which might lead to discrimination or involve a serious risk for a Data Subject if misused. This includes Personal Data that may reveal personal aspects of an individual, such as race, ethnic origin, health condition, genetic information, religious, philosophical, or moral beliefs, labor union membership, political opinions and/or sexual orientation. All capitalized terms used in this Clause that are otherwise not defined shall have the same meaning expressed in the Mexican Data Protection Legislation.
Personal Data Collected
- Identity Information.
- Financial Information.
- Equity Information.
- Tax Information.
- Labor Information.
- Academic Information.
- Legal Information.
- Geolocation data.
- Sensory data.
- Information regarding the Client-Attorney relationship.
To comply with the Mexican Data Protection Legislation, we expressly inform you that we could collect and process the following Sensitive Personal Data:
- Criminal history.
- Health or disability specifics.
Purpose of Collection
The necessary purposes of processing your Personal Data are set out in the section “How We Use Your Personal Information.” We will process your personal data for the following necessary purposes:
- To provide legal services.
- To establish a legal relationship.
- To maintain communication with you.
- To comply with legal and competent authorities’ requirements.
- To protect our legal interests.
- To verify your identity to respond to your requests regarding our collection, processing, and/or retention of your Personal Information.
- Respond to your comments, inquiries, and/or provide you with information you request.
- For the recruiting and selection process.
- To market legal publications and events that we sponsor or otherwise present.
- Maintain the security and improve the functionality of our website.
- To control access and maintain security at our facilities.
Likewise, we can process your data for the following optional purposes, which are not necessary, but they allow us to offer you a better service if you don’t oppose through the available means that are described in the section “ARCO Rights and other rights”:
- For marketing legal services.
- To accommodate your dietary preferences at firm events.
- The type of browser, operating system, and your Internet Protocol (IP) address;
- The time, date, and length of your visit; and
- The pages within our website that you visit.
The purposes for which we use this personal data are:
- To identify the pages are accessed by our website visitors in order to improve and expand content that adds to the value of the content our website visitors are accessing.
- To identify the preferences of our website visitors to improve our website content.
- To provide you with the service(s) in which you have expressed an interest while visiting our website.
- For maintenance of our website.
The third parties with which we may share this data are:
|Website Service Provider||
|Google (Google Analytics)||
If we transfer your personal data, we will ensure the recipient will provide a standard of protection that complies with the same level of protection established in the Mexican Data Protection Legislation.
We inform you that your personal data is shared internally and abroad with the following receivers other than us for the following purposes:
|Legal and competent authorities||
When you accept this Privacy Notice, you allow Snell & Wilmer to transfer your Personal Data if your consent is needed, as indicated in the above table (if applicable). However, you can oppose to the data transfer at any time using the mechanism provided in the section below.
ARCO Rights and Other Rights
At Snell & Wilmer we acknowledge that you have, as a Data Subject, the right to request access to your Personal Data and to know how it is processed, to request its rectification in case it is inaccurate or out of date, and to request its cancellation or deletion in a secure manner, where this is applicable. You may also object to the processing of your Personal Data on legitimate grounds (these rights are commonly referred to as "ARCO Rights"), may request limitation of the use or disclosure of your Personal Data, manifest your refusal to optional purposes or revoke the consent you have given us for the processing of your Personal Data.
You can exercise any of the above rights by sending an email to PrivacyOfficer@swlaw.com, by phone at 1.800.949.0225, by clicking on the “Do Not Share or Sell My Information” button at the bottom of any page of our website, swlaw.com, or by sending your request by mail to Privacy Officer, Snell & Wilmer, One East Washington Street, Suite 2700, Phoenix, AZ 85004, U.S.A.
Please note that your request must contain at least the following information:
- Name, address or other means of communicating the response;
- A document proving your identity or personality as the representative of the holder of the Personal Data;
- A clear description of the Personal Data for which you wish to exercise a right and name of the right;
- Elements or documents that facilitate the location of the data; and
- In case of requesting the right of rectification you must indicate the modifications corresponding to the Personal Data.
We will respond to your request within 20 working days from the date of receipt. If applicable, we will act on your request within 15 working days of sending our first response.
It will be understood that we have given you access to your Personal Data when we make it available to you, regardless of what means or format it is made available to you, as long as it is understandable.
We have designated a Data Protection Officer to answer any request or doubts regarding this Privacy Notice. You may contact this individual by email at PrivacyOfficer@swlaw.com, by phone at 1.800.949.0225, or by mail. Our address is Privacy Officer, Snell & Wilmer, One East Washington Street, Suite 2700, Phoenix, AZ 85004, U.S.A.
Changes to the Privacy Notice
Snell & Wilmer reserves the right to amend this Privacy Notice for Mexican Data Subjects at our discretion at any time. When we make substantive changes to this Privacy Notice, we will post a summary at the top of the first page of this Notice and update the Notice effective date. Please be sure to visit our website to see if updates have been made.
Our website is not targeted to children under the age of 18. We do not knowingly collect Personal Information from any child visiting our website. If we become aware that such data has been collected, we will delete it.
Personal Information directly from children under the age of 18 is generally obtained through parental consent or the guardian consent. A child’s parent or guardian may also exercise any ARCO right by emailing us at PrivacyOfficer@swlaw.com.
You agree to give your explicit written consent for the processing of Personal Data (including Sensitive Personal Data) as well as data transfers that require your consent according to the terms established in the Privacy Notice.
( ) I confirm that I have obtained the authorization of the third parties whose personal data I delivered to Snell & Wilmer for them to process such data according to this Privacy Notice, and I have provided a copy of the Privacy Notice to those third parties.Name: