This Global Privacy Notice describes how Troutman Pepper Locke LLP, its wholly owned subsidiaries, and Troutman Pepper Locke (UK) LLP (collectively, “Troutman Pepper Locke,” “we,” “us,” or “our”) collect, use, share, or otherwise process information that identifies you or could reasonably be used to identify you (“Personal Data”). Unless otherwise specified, Troutman Pepper Locke is the controller of and responsible for the Personal Data we process under this Global Privacy Notice.
This Global Privacy Notice applies to Personal Data that Troutman Pepper Locke processes online and offline when you visit our offices, use our websites or mobile applications, attend our virtual or in-person events, receive our emails, or otherwise communicate with us, including in connection with certain professional legal services we provide (collectively, the “Services”). Troutman Pepper Locke primarily offers Services in the business-to-business context.
NOTE: If you reside in certain U.S. jurisdictions with state privacy and data protection legislation, please refer to our U.S. State Privacy Law Notice at Collection for additional information concerning our data processing practices and your rights. If you work for Troutman Pepper Locke or apply for a job with us, please see our Worker and Applicant Global Privacy Notice, which describes how we process your Personal Data.
The types of Personal Data that we collect about you depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources, such as third-party services and organizations, as described below. If we are required by applicable law or by the terms of a contract to collect your personal data and you fail to provide the necessary information to us, we may not be able to provide you with Services you requested or otherwise perform under our contract with you. For residents of the UK, EU, and certain U.S. states with comprehensive privacy laws, additional disclosures about the information we collect is contained in the Supplemental Disclosures below.
a) Information You Voluntarily Provide to Us. We collect Personal Data that you voluntarily provide to us. This includes, for example, Personal Data you provide when you contact us (including when contacting us on behalf of an organization with which you are affiliated); when you request alerts, event invitations, newsletters, or other informative materials; or when you register for a webinar or event, fill out a form, respond to a survey, or otherwise communicate with us. The categories of Personal Data that we may collect directly from you include:
Identifiers, such as your name, physical address, email address, telephone number, bar number, signature, government-issued identification number, and account credentials (e.g., username) if you access or use a Troutman Pepper Locke online service, or other similar identifiers.
Professional and Educational Information collected in the business context, such as your current or previous employers, your job title, information about the organization with which you are affiliated, or professional qualifications, such as your bar number, degrees, professional memberships, qualifications, and certifications.
Contact Information and Preferences, such as your stated interests, meal or other preferences when attending events we host, information you would like us to use to contact you, and how frequently you wish to receive our publications or communications.
Audio and Visual Information, such as your voice and likeness as captured in photographs, video, or audio recordings, if you attend our events, visit our offices, or leave us a voicemail message.
Commercial information, such as records of services you obtained from us, including on behalf of an organization with which you are affiliated.
b) Information We May Collect Automatically. We, as well as third parties that provide content, analytics, or other functionality to support our online Services, may use cookies, pixel tags, and other technologies (collectively, “Collection Technologies”) to automatically collect certain types of information when you interact with us and our Services online. The types of information we collect in this context may include:
Identifiers, such as information that uniquely identifies you, such as your name, email address, and username.
Device Information, such as information pertaining to the device through which you interact with our Services, such as your IP address, type of device, operating system and version, MAC address, user settings, or browser type.
Internet or Other Electronic Network Activity Information, such as your browsing history, search history, and information regarding your interactions with us and our Services, which may include pages that you visited while using our Services, the links you click, the types of content with which you interact, the frequency and duration of your activities, and other information about how you use our Services.
Geolocation Information, such as the region or general location where your computer or device is accessing the internet.
c) Information We Collect from Other Sources. We may obtain Personal Data about you from other sources, such as our clients, employees, and business partners, or from business contact databases and enrichment services. We may also receive or obtain information about you from social media platforms, such as when you interact with us on those platforms or access our social media content. We may collect information about you from publicly available sources, such as public social media profiles, publications, and other websites or materials available through search engines. We may collect the following categories of Personal Data from these other sources:
Identifiers, such as name, telephone number, postal or email address, government-issued identification number, and social media identifiers.
Professional and Educational Information collected in the business context, such as your current or previous employers, business contact information, job title, languages, information about the organization with which you are affiliated or professional memberships, qualifications, licenses, and certifications.
Case or matter related data provided by clients, other parties to a matter, courts, government agencies, professional advisors, service providers, consultants, experts, arbitrators, from our own investigations in connection with representing our clients, and from other third parties providing such data.
2) How We Use Personal Data
We will only use your Personal Data for lawful purposes. Specifically, we may use your Personal Data for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our Services, as described below. More information about the legal basis for each of these purposes under applicable data protection laws is set forth in our Supplemental Disclosures.
We will only use your Personal Data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose as specified in applicable data protection laws. If we need to use your Personal Data for a purpose that we have not specified in this Global Privacy Notice, we will notify you where we are required by applicable data protection laws to do so, and we will explain the legal basis which allows us to do so, or seek your consent, as required.
a) We use Personal Data to provide our Services and Communicate with You, including when you contact us with a comment, request, or question; when you register for an event or webinar; when you request legal services; when we send you announcements, invitations, publications, and other information or materials that may interest you; when we send you technical notices, updates, security alerts, and other administrative messages: and to personalize your experiences with us, including to remember your interests and preferences, and facilitate interactions and introductions.
b) We use Personal Data for our Administrative, Regulatory, and Compliance Purposes, such as to operate, troubleshoot, repair, and improve our websites, mobile applications, and other digital properties; secure or enhance our Services administer and enforce our agreements and policies (including without limitation, this Global Privacy Notice) and notify you of changes; carry out activities that are required to comply with our legal obligations imposed by law, regulation, decree, court order, or legal settlement); investigate illegal activities, suspected fraud, or potential threats to the safety of any person; provide evidence in litigation in which we or our clients are involved; and other legitimate business purposes as permitted by law.
c) We Use Personal Data to Market and Advertise our Services in accordance with our professional obligations, internal guidelines, and applicable law. This includes, for example, when we use Personal Data to distribute our publications, offer online events, and measure interest and engagement in our Services.
d) To De-identify and Aggregate Information. We may use Personal Data to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create. We may use this de-identified or aggregated data for the purposes outlined in this Global Privacy Notice and afford it appropriate protections as required by applicable data protection and other laws.
e) We Use Personal Data for Other Purposes with your consent, as requested by you, or as required or permitted by applicable law.
3) How We Disclose Personal Data
We may disclose your Personal Data to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. We may also disclose your information with third parties as required, appropriate, or otherwise permitted by law.
a) Disclosures to Provide our Services. We may disclose your Personal Data to the following categories of third parties to provide our Services:
Service Providers. We may disclose your Personal Data to third parties that provide services on our behalf or help us operate the Services (such as customer support, website hosting, data analytics, email delivery, marketing, and database management services). Our third-party service providers use your Personal Data only as directed or authorized by us and are prohibited from using or disclosing your information for any other purpose.
Professional Advisors. We may disclose your Personal Data to our professional advisors, such as lawyers, auditors, and insurers, when necessary. Our professional advisors use your Personal Data only as directed or authorized by us and are prohibited from using or disclosing your information for any other purpose.
Affiliates. We may disclose Personal Data to our affiliates (other entities owned, controlled, or under common ownership with the firm) for administrative or regulatory compliance purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
Social Networks. Your Personal Data may be disclosed to us and others via social networks if you visit our social media accounts by clicking a social media widget from our online properties (e.g., YouTube, X, or LinkedIn).
b) Disclosures to Protect Us or Others. We may disclose Personal Data for legal or compliance purposes including:
For Legal Compliance and Safety. We may disclose your Personal Data for compliance, fraud prevention, and safety reasons in connection with legal proceedings or to respond to a legal inquiry or mount a defense to an allegation in a legal or regulatory context.
To Comply with Legal Process or in the Public Interest. We may access and disclose personal data or information we can associate with you to external parties if we believe in good faith that doing so is required or appropriate to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; to protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
In the Event of Merger, Sale, or Other Asset Transfers. We may disclose your Personal Data in connection with a business transaction (or potential business transaction), such as a merger, consolidation, acquisition, or in connection with a reorganization, bankruptcy, or dissolution.
c) Disclosures with your Consent or Instruction. We may also disclose your Personal Data when we have your consent or instruction to do so, for example, providing your name and contact information to a co-sponsor of an event that you attend or a co-author of a publication you request.
4) Retention of Personal Data
We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Global Privacy Notice, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data, in each case in line with our data retention policies, unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your Personal Data to comply with our legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another business purpose.
5) Online Collection Technologies
Troutman Pepper Locke and our Service Providers may use Collection Technologies to gather the information described above when you use, access, otherwise interact with our Services. We may use Collection Technologies in various ways, as described by the following categories:
a) Essential Technologies. These Collection Technologies are essential to our ability to offer our Services and include technologies that allow you access to our Services, applications, and enable tools that we use to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of embedded functionalities or features of our Services.
b) Analytics/Performance-Related Technologies. These Collection Technologies allow us to better understand how our digital Services are used and to improve and personalize our Services.
c) Functionality-Related Technologies. These Collection Technologies allow us to operate our Services and offer enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past viewing activities.
d) Social Media Platforms. If you visit one of our social media accounts, the social media site, like any other third-party site, may collect Personal Data. Your interactions with these platforms are governed by the privacy policy of the company providing it.
6) Your Privacy Choices
The privacy choices you have about your Personal Data are determined by your specific circumstances, the context, and applicable law, and are described below.
a) Managing Communication Preferences. If you no longer wish to receive marketing communications from us, please Contact Us at any time. Our digital marketing communications may provide unsubscribe or opt out mechanisms. Please note that if you opt out of marketing communications, we may still contact you with non-promotional communications, such as those about ongoing business relations or administrative messages.
b) Managing Cookie and Other Collection Technologies Preferences. When you first visit our website, you will be presented with a banner which offers you a choice about whether to accept or reject cookies or Collection Technologies of different types, except for those cookies and Collection Technologies that are necessary for the operation of our sites. You may choose to “Accept” or “Decline” our use of such cookies and Collection Technologies. To revisit your choice, you must first clear the cache and cookies in your web browser.
c) Browser Controls. You may also stop or restrict the placement of certain Collection Technologies in your browser or remove them by adjusting your preferences as your browser permits. These tools are generally available in the help section of browsers. You can also use the quick links, based on the browser type that you are using Internet Explorer, Google Chrome, Firefox, and Safari.
d) Mobile Device Controls. You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. Please note that cookie-based opt-outs may not stop all mobile tracking, such as tracking done on mobile applications.
e) Ad Industry Opt-outs. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from companies that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance. Please note you must separately opt out in each browser and on each device.
f) Service Providers. Our service providers include third-party analytics providers (e.g., Google Analytics) that may use Collection Technologies in support of our research and analytics efforts, including to better understand your use of our Services, improve those technologies, and optimize your experience and interactions. For more information about how Google Analytics uses information and learn how to opt-out of Google Analytics’ use of your information, please visit Google Analytics’ Privacy Policy.
7) Your Privacy Rights
In accordance with applicable law, you may have various privacy rights, as outlined below. If you would like to exercise any of these rights, please Contact Us at any time. We will process such requests in accordance with applicable law and will not discriminate or retaliate against you for the exercise of any privacy rights granted to you.
a) Access and Obtain a Copy of your Personal Data, including to: (i) confirm whether and how we are processing your Personal Data; (ii) obtain access to or a copy of your Personal Data; (iii) receive an electronic copy of Personal Data that you have provided to us; (iv) receive automated information where our processing is based on consent or the performance of a contract with you; or (v) request data portability (asking us to send that information to another company in a structured, commonly used, and machine-readable format).
b) Request Correction of your Personal Data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to do so.
c) Request Deletion of your Personal Data which enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it, when you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local laws. Note, however, that we may not always be able to comply with your request to delete your Personal Data for specific legal reasons of which we will notify you, if applicable, at the time of your request.
d) Request Restriction of or Object to our processing of your Personal Data where the processing of your Personal Data: (i) is based on our legitimate interest for direct marketing purposes; (ii) involves processing or sharing of your sensitive Personal Data for certain non-essential purposes, or in contexts that require your consent; and (iii) for profiling in furtherance of decisions that produce legal or similarly significant effects that concern you.
e) Withdraw your Consent to our processing of your Personal Data. Where our processing is based on your consent or subject to your objection, please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal. See our U.S. State Privacy Law Notice at Collection for more details.
f) Appeal. You may have the right to appeal our response to your request. To exercise your right to appeal, you can submit an appeal request using the same method used to submit your original request, including by Contacting Us.
g) Lodge a Complaint. While we are always willing and eager to listen and respond to your concerns about this Global Privacy Notice or our data practices, at any time you have the right to lodge a complaint with the data protection authority or other regulatory body in charge of enforcing data protection laws in your jurisdiction.
8) Security Practices
We have implemented certain administrative, physical, and technical security measures to help protect against loss, misuse, or alteration of your Personal Data. While we use reasonable security procedures to protect your Personal Data, no method of transmission over the Internet is 100 percent secure. As a result, we cannot guarantee the absolute security of your Personal Data. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of Personal Data.
9) International Data Transfers
We may transfer, process, and store all information collected via or by Troutman Pepper Locke anywhere in the world, including, but not limited to, the United States. To the extent personal data is transferred from the United Kingdom (“UK”) or the European Union (“EU”) to the United States or other jurisdictions that require valid safeguards to be in place, and unless an exemption applies, Troutman Pepper Locke will adopt sufficient legal safeguards (such as standard contractual clauses) and will conduct relevant transfer impact assessments where applicable. For more information about the safeguards we use for international transfers of your Personal Data, please Contact Us at any time.
10) Children
Our Services are intended for and directed exclusively to adults. We do not knowingly collect Personal Data directly from individuals under the age of majority in their relative jurisdictions. If we become aware that a “child,” as defined in by the laws of their applicable jurisdiction, has provided us with Personal Data, we will delete the information from our records unless we have a legal obligation to keep it.
11) Links to Other Websites and Services
Our Services may contain links to websites/applications, and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage you to read the privacy policies of each website and application with which you interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing Personal Data to third-party websites or applications is at your own risk.
12) Changes to this Global Privacy Notice
We may update this Global Privacy Notice periodically, noting the date of revision. If we make any material changes in the way we collect, use, and/or disclose Personal Data, we will endeavor to provide you with notice before such changes take effect, such as by posting a prominent notice on the Troutman Pepper Locke website.
13) Contact Us
We welcome your inquiries and comments. If you are not a client, we may not be able to treat the information that you send us as confidential or privileged. If you wish to contact us regarding legal representation, please contact an attorney in one of our offices near you. You can find a list of our offices and our attorneys on our website.
If you have questions about our information practices or wish to exercise a privacy right, please contact us using the following methods:
Mail: Troutman Pepper Locke LLP, Attention: General Counsel, 600 Peachtree Street, Suite 3000, Atlanta, GA, 30308
The data controller is Troutman Pepper Locke LLP or in respect of Services provided by, involving, or data collected by or provided to Troutman Pepper Locke (UK) LLP, it is a joint data controller.
We do not use automated decision-making technology.
In addition to the rights identified at section 7 above, you may additionally lodge a complaint with your data protection supervisory authority. If you reside in the UK, this is the Information Commissioner’s Office (“ICO”). If you are in the EU, information about your national supervisory authority can be found here.
The table below contains a list of the legal bases on which we rely when processing Personal Data that is subject to applicable data protection laws in Europe, including the EU General Data Protection Regulation (the “EU GDPR”) and the EU GDPR as it forms part of retained EU law in the United Kingdom, (the “UK GDPR”). For our workers and applicants who reside in the UK and the EU, please refer to our Worker and Applicant Global Privacy Notice for additional information. Please also note that if your Personal Data is subject to the EU GDPR or UK GDPR, you may receive a copy of the safeguards we use to protect your personal data when it is transferred internationally on request.
We rely on the following legal bases for the processing of your Personal Data.
Processing Purpose
Categories of Data
Applicable Legal Bases
Provide our Services
– Identifiers – Professional and Educational Information – Contact Information and Preferences – Audio and Visual Information – Device Information – Commercial information – Internet or Other Electronic Network Activity Information – Geolocation Information
Performance of a contract with you; necessary for our legitimate interests (e.g., to manage our relationship with you; to keep our records updated and resolve customer issues; to improve, personalize, and develop the services we offer you; and to communicate with you about your use of our services); and with your consent.
Administrative, Regulatory, and Compliance Purposes
– Identifiers – Audio and Visual Information – Professional and Education Information – Device Information – Commercial Information – Internet or Other Electronic Network Activity Information – Geolocation Information
Performance of a contract with you; Necessary to comply with a legal or regulatory obligation (including the defense of claims); Necessary for our legitimate interests (e.g., to operate our business; to provide administrative and IT services and network security; to prevent fraud; to maintain current business records, study how customers use our products/services, resolve customer issues, improve our sites, and support personalized features; to detect and resolve technical problems; and to develop our business); and with your consent.
Marketing and Advertising Purposes
– Identifiers – Audio and Visual Information – Professional and Educational Information – Internet or Other Electronic Network Activity Information – Contact Information and Preferences – Commercial Information
Necessary for our legitimate interests (e.g., to study how customers use our products/services, to develop them, and to develop and grow our business); Consent if required by law (e.g., for use of non-essential cookies)
Biometric Data: While we may process biometric data that we are provided in connection with Services we offer to our clients, we do not otherwise collect biometric data.
Special Category Data: Where we process special category data, we will only do so when it is necessary, and we have both a legal basis for doing so where one of the additional conditions under the GDPR applies and we have completed and retained an appropriate policy document and a record of processing activity. The legal basis, in relation to cases or matters handling is legitimate interest, to comply with a legal obligation, to comply with a contractual obligation or, occasionally, with your explicit consent. In addition, one or more of the following additional bases may apply: preventing or detecting unlawful acts, regulatory requirements, preventing fraud, protecting the public, or suspicion of terrorist financing or money laundering.
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