Privacy Policy | Littler GPS

Effective Date: May 18, 2021

Littler Mendelson, P.C. (Littler, or “us”, “we”, and “our”)
respects and values your privacy and we are dedicated to sharing our methods
and approach to how we collect, use, share, and protect your personal information
in this policy (“Privacy Policy”). This Privacy Policy describes how Littler
handles personal information:

From visitors to our website or web-based applications
(“Websites”)
Through software applications made available by us for use on or
through computers and mobile devices (“Apps”)
Contacts at our clients and/or prospective clients
Contacts for suppliers of goods and services to Littler
From any other individual about whom Littler obtains personal
information in the provision of legal services to our clients (“Client
Services”)
From those who apply to work for us

The items outlined above are collectively called “Services”.
Littler Global firms may have their own Privacy Policies that govern their
collection and use of personal information in the provision of their services.

Information We Collect About You

For the purposes of this Privacy Policy, Personal
Information is information that relates to an identified or identifiable
person, whether alone or in combination with other information. Littler
collects the following types of Personal Information:

Contact and Basic Information: name, title, phone numbers,
organization, job responsibilities, gender, mailing address, and email address.
Registration Information such as information necessary to
process or respond to newsletter requests, event/seminar registration, dietary
preferences (excluding special categories), subscriptions, requests to download
information, and usernames/passwords.
Marketing Data such as information about individual
participation in conferences and in-person seminars, credentials, associations,
product interests and preferences.
Compliance Data: government identifiers, passports or
other identification documents, date of birth, beneficial ownership, and due
diligence data.
Special Categories: in limited circumstances, Littler
receives special categories of Personal Information as is necessary for a
specific service we are providing to you, your employer or any other
organization you may by affiliated with. Examples of Special Categories
include: social security numbers, religious or other beliefs, racial or ethnic
origin, sexual orientation, health data and details of trade union membership.
Client Service Information: Personal Information received
from clients regarding their employees or other individuals known to clients,
invoicing details and payment history, and client feedback.
Device Data: IP address, unique device identifiers,
cookies and other data linked to a devices, and data about the usage of our
Websites.
Job Applicant Data: Data provided by job applicants or
others on our Website or offline in connection with employment opportunities.

Cookies and Similar Technologies

Our Websites use cookies and similar technologies to enhance
your experience when viewing the Websites and to compile statistical
information regarding their use. A cookie is a file that is transmitted by a
website to a user’s browser. The browser then saves that file in a designated
file for cookies on your computer or device. We use cookies to allow us to
personalize your experience, compile statistics about how the Websites are
used, including the most popular pages. We use pixels (clear GIFs and web
beacons) to track the actions of users of our Websites and email recipients,
measure the success of our marketing campaigns, track whether our emails are
forwarded, and compile statistics about usage of our Websites and email
response rates.

We do not currently respond to do-not-track signals. If you
do not want information collected through the use of cookies, most browsers
allow you to automatically decline cookies or be given the choice of declining
or accepting a particular cookie (or cookies) from a particular website. You
can review https://www.allaboutcookies.org
for more information. Please note, that if you do not accept cookies, you may
experience some inconvenience in your use of our Websites.

We also use Google Analytics, which uses cookies and similar
technologies to collect and analyze information about the use of services and
report on activities and trends. You can learn about Google’s practices href="https://policies.google.com/technologies/partner-sites">here.

Sources of Personal Information

Littler may collect Personal Information from a variety of
sources, including:

Through our provision of Services, for example, when you sign-up
for a newsletter, request Services from Littler, register for a seminar, enter
into a contractual relationship for Services, interact with us at an event,
visit our Websites or networks, use our online applications, apply for a job,
send us communications, or call or visit a Littler office.
From other sources including:
- Publicly available and subscription-based sources
- Court documents and filings
- Event sponsors
- Our clients
- Counterparties in transactions or disputes
- Social media
- Our service providers

Littler needs to collect Personal Information in order to
provide the requested Services to you or to provide Services to our clients. If
you do not provide the information requested, we may not be able to provide the
Services. Where Littler receives Personal Information from its clients about
employees or other individuals, the client is responsible for ensuring that any
such Personal Information is transferred to us in compliance with applicable
data protection laws and regulations.

Uses of Personal Information:

The purposes for which Littler uses Personal Information,
and the legal basis for such use are as follows:

The provision of legal advice/services and response to inquiries.
We engage in this activity to fulfil our ethical, legal and contractual
obligations with our clients.
Management of our business operations and administration of our
client relationships. We engage in this activity to fulfil our ethical, legal and
contractual obligations with clients and suppliers.
Enhancing the functionality of our Websites. We engage in this
activity because we have a legitimate interest in monitoring how our Website
and Apps are used to help us provide better services to our Website and App
users.
Fraud and security monitoring purposes. We engage in this
activity because we have a legitimate interest to detect and prevent fraud,
crimes and other misuses of our Websites and networks.
Data analysis, to improve the efficiency of our Services and
identify trends. We engage in this activity to manage our relationships with
clients, to comply with legal obligations, and/or because we have other
legitimate interests.
Auditing internal process for proper functioning. We engage in
this activity to manage our relationships with clients, to comply with legal
obligations, and/or because we have other legitimate interests.
To provide relevant marketing materials. We engage in this
activity because we have a legitimate interest or because we have obtained
consent.
Compliance with legal and regulatory obligations. We engage in
this activity to manage our relationships with clients, to comply with legal
obligations, and/or because we have other legitimate interests.
To evaluate and consider individuals for employment and manage
on-boarding procedures. We engage in this activity because we have a legitimate
interest and/or to comply with our legal obligations.

Littler may aggregate and/or anonymize Personal Information
so it is no longer considered Personal Information. We do this to generate
other data for our use, which we may use and disclose for any purpose.

Disclosure of Personal Information

We may disclose Personal Information to:

Our subsidiaries, affiliates and joint venture partners
Contractors, vendors and services providers
Counterparties to transactions or disputes, and their counsel
Courts, arbitrators, mediators, and others as necessary to
represent our clients

We may also disclose Personal Information as necessary to:

Comply with applicable laws and regulations
To cooperate with public and government authorities
To cooperate with law enforcement
To enforce our terms and conditions
To protect our rights, privacy, safety or property, and/or that
of our affiliates, or others.
Effectuate any reorganization, merger, sale, joint venture,
assignment, transfer or other disposition of all or any portion of our
business, assets or stock (including in connection with any bankruptcy or
similar proceedings) with a third party

Protection of Personal Information

We have implemented reasonable measures to secure Personal
Information from accidental loss or destruction and from unauthorized access,
use, alteration and disclosure. Unfortunately, no transmission or storage
system can be guaranteed 100% secure.

Information Relating to Minors

The nature of our services is not intended for individuals
under the age of 16.

Cross-Border Data Transfers

We may transfer Personal Information to jurisdictions as
necessary for the purposes described above, including to jurisdictions that may
not provide the same level of protection as your country of residence. By using
our Services, you understand that your information will be transferred to the
United States or to other countries in which Littler or Littler Global firms
may exist.

For transfers of Personal Information from the European
Economic Area (EEA) to countries not considered adequate by the European
Commission, Littler has put in place adequate measures, such as the standard
contractual clauses adopted by the European Commission, to protect Personal
Information.

Choices and Access

You have choices regarding marketing-related communications.
If you no longer want to receive marketing-related emails from Littler, you may
opt-out by following the unsubscribe instructions in our marketing emails.

If you would like
to request to review, correct, update, suppress/delete, or object to or
restrict processing of your Personal Information, or if you would like to
request to receive an electronic copy of your Personal Information for purposes
of transmitting it to another company, please contact us in accordance with
the Contact Us section below. We will respond to your request
consistent with applicable law. If you are a California resident, please refer
to the "Additional Information Regarding California" section at the end of this
Privacy Policy for more information about the requests you may make under the
CCPA.

In your request,
please make clear what you are seeking in your request, including what Personal
Information is subject to your request. For your protection, we may need to
verify your identity before implementing your request. We will try to
comply with your request as soon as reasonably practicable.

Retention Period

We will retain
your Personal Information for as long as you are a client, the performance of
our Services requires, and as long as our ethical obligations require.

Third Party Websites

The Website and
Apps may contain links to unaffiliated third parties, such as Facebook,
Twitter, and LinkedIn. This Privacy Policy does not apply to such third-party
sites. When you click a link to visit a third-party website, you will be
subject to their website’s privacy practices. We encourage you to review the
privacy and security practices of any linked third-party website before
providing any Personal Information on that website.

Contact Us:

If you have questions or concerns regarding our Privacy Policy or practices, you may
contact us using the following details:

Email Address: Privacy@littler.com
Postal Address:

Littler Mendelson, P.C.

Attention: Information Protection and Privacy

1300 IDS Center, 80 South 8^th Street

Minneapolis, MN 55402

Changes to this Privacy Policy

Littler may update this Privacy Policy from time to time.
When we do, we will post the current version on this site, and we will revise
the version date located at the top of this page. Any changes become effective
when we post the revised Privacy Policy. Your continued use of our Services
following these changes means that you accept the revised Privacy Policy.

Additional Information Regarding the EEA

You can lodge a complaint with the data protection authority
for your country or region, or where the alleged infringement of applicable
data protection law occurs. However, before doing so, we encourage you to
contact us directly to give us an opportunity to work directly with you to
resolve any concerns about your privacy.

Additional Information Regarding California

California Consumer Privacy Act of 2018 (CCPA)

Pursuant to the CCPA, we are providing the following
additional details regarding the categories of Personal Information about
California residents that we collected and disclosed in the preceding 12
months. This policy does not apply to our job applicants, employees,
contractors, owners, directors, or officers where the Personal Information relates
to their current, former, or potential role at Littler. California job
applicants can review Littler’s href="https://videsktop.littler.com/visurveyex/ccpa/ccpanotice.pdf">Notice for
Job Applicants Residing in California for more information.

We collected the following information:

Category of Personal Information:	Business Purpose:	Personal Information was collected from the following categories of sources:	Personal Information was disclosed to the following categories of third parties:
Audio, electronic, visual, thermal, olfactory, or similar information	Audio/Visual – where required for regulatory reasons, to keep record of client instructions or other matters discussed To transcribe or prepare a written note of client interviews	Conference calls and video conferences with clients and other third parties Interviews with clients as part of client feedback program Video surveillance when visiting a Littler office Voicemail messages Audio and/or video recordings of interviews or depositions	Our affiliates Suppliers and service providers where necessary to perform functions on our behalf Opposing parties, their counsel, courts, arbitrators, mediators, and others as necessary to represent our clients
Identifiers such as real name, alias, IP address, email address, account name, unique online identifier, social security number, driver’s license number, passport number, or other similar identifiers.	To provide legal advice, business services, and to respond to inquiries To manage our business operations and administer our client relationships To provide relevant marketing to you or your employer To address compliance and legal obligations (e.g. checking identity of new c lients, prevention of fraud/money laundering, to protect the security of our networks, devices, and information) Mandatory disclosures and legal claims (e.g. to comply with any subpoena, court order or other legal process or to comply with any regulatory, governmental or legally binding request)	Directly from the individual Our affiliates Counterparties to transactions or disputes Employers (i.e. clients) Agents or professional advisors authorized to disclose data on behalf of the individual Publicly available or subscription-based sources
Personal Information Categories from Cal. Civ. Code §1798.80(e)including 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, medical information, or health insurance information. *"Personal information" does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
Commercial Information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Characteristics of Protected Classifications under California or Federal Law Race, age, national origin, disability, sex, veteran status, philosophical or religious beliefs, sexual orientation, disability, gender identity, gender expression, marital status, familial status	Only as strictly necessary for the purposes identified above Solely to the extent required to comply with Littler’s legal or other best practice obligations (e.g. AML, equality laws, monitoring diversity and inclusion, etc.)
Inferences Drawn from any of the PI identified above	We may draw inferences from information that we have received (such as, we may draw inferences from evidence received from or on behalf of our clients in legal proceedings; we may conclude that you are interested in receiving updates from us on developments in particular areas if you have attended firm-sponsored events; or we may conclude that applicable laws prohibit us from engaging with a prospective client based on information obtain through our Know-Your-Client compliance procedures)
Professional or employment-related information	To provide relevant marketing to you (e.g. information about events or services that may be of interest) To provide legal advice, business, services and to respond to inquiries		Our affiliates Suppliers and service providers where necessary to perform functions on our behalf
Internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement	To make our website for intuitive To protect the security of our networks, devices, and information	Via the firm’s Website or Apps	To our service providers to the extent necessary for the provision of services on our behalf

Disclosure of Personal Information, No Sale

Littler has not sold Personal Information as defined or as
contemplated by the CCPA in the preceding 12 months. As defined and
contemplated by the CCPA, Littler does not sell Personal Information of minors
under the age of 16.

California Consumer Privacy Rights

As a California Consumer, you have the following rights:

Right to Disclosure: California Consumers have a right to
request information from Littler regarding the Personal Information Littler
collects and discloses for business purposes about the consumer.
Deletion: In certain circumstances, you have the right to
request we delete Personal Information we collected from you. Please note that
the right to request deletion is subject to certain exceptions under the CCPA.
Non-Discrimination: Littler will not discriminate against
California Consumers for exercising their rights under the CCPA.

Littler does not offer financial incentives or price or
service differences in exchange for the retention of a California Consumer’s Personal
Information.

How to Submit a Verifiable Request

Littler will respond to requests in accordance with the CCPA
if it can verify the identity of the individual submitting the request.
California Consumers can exercise these rights by contacting (888) 548-8537 or
by email at privacy@littler.com. We
may not be able to comply with your request if we are unable to confirm your
identity or connect the information you submit in your request with Personal Information
in our possession.

Authorized Agent

A California Consumer may designate an Authorized Agent
registered with the California Secretary of State to submit a disclosure or
deletion request on behalf of the Consumer. For Littler to respond to a request
from an Authorized Agent, Littler may:

Request a copy of the written permission granting the Authorized Agent to make such a request on the consumer’s
behalf; and
Verify the identity of the consumer.

Littler may deny a request from an Authorized Agent that
does not submit proof that they have been authorized by a consumer to act on
their behalf.