Safe Harbor Privacy Policy
Paul Hastings respects individual privacy and values 
the confidence of its employees, clients and business partners. In addition to collecting, processing and disclosing personal information in a manner consistent with the laws of the countries in which we do business, we also follow our Client Service Excellence Principles in our business practices. Our Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles established by Paul Hastings with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States.
SAFE HARBOR
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that ensures adequate protection for personal information transferred from the EEA to the United States (the "U.S.-EU Safe Harbor"). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with our commitment to protect personal privacy, Paul Hastings adheres to the principles set forth in the U.S. - EU Safe Harbor.
SCOPE
This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by Paul Hastings in the United States from the EEA including electronic, paper or verbal.
DEFINITIONS
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Paul Hastings or to which Paul Hastings discloses personal information for use on Paul Hastings’ behalf.
“Paul Hastings” means Paul Hastings LLP, Paul Hastings (Europe) LLP, and each of their predecessors, successors and affiliates.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of Paul Hastings to identify an individual. Personal information does not include information that is anonymous or encoded, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” consists of data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life, or information on criminal activity or proceedings. In addition, Paul Hastings will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
PRIVACY PRINCIPLES
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
NOTICE: Where Paul Hastings collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which Paul Hastings discloses that information, the choices and means, if any, Paul Hastings offers individuals for limiting the use and disclosure of personal information about them, and how to contact Paul Hastings. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Paul Hastings, or as soon as practicable thereafter, and in any event before Paul Hastings uses or discloses the information for a purpose other than that for which it was originally collected.
Where Paul Hastings receives personal information from other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: Paul Hastings will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, Paul Hastings will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
DATA INTEGRITY: Paul Hastings will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Paul Hastings will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: Paul Hastings will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Paul Hastings has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Paul Hastings will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, Paul Hastings will grant individuals reasonable access to personal information that it holds about them. In addition, Paul Hastings will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: Paul Hastings will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: Paul Hastings will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Paul Hastings determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to Paul Hastings Human Resources at the address given below. Paul Hastings will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Paul Hastings and the complainant, Paul Hastings has committed to use an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Paul Hastings, you may contact the BBB EU SAFE HARBOR program at the address below:
Council of Better Business Bureaus, Inc.
BBB EU SAFE HARBOR
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: www.bbb.org/us/safe-harbor-complaints
For unresolved complaints related to Paul Hastings’ human resources data, Paul Hastings will cooperate with the European Data Protection Authorities (DPAs).
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Paul Hastings to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
INTERNET PRIVACY
Paul Hastings sees the Internet and the use of other technology as valuable tools to communicate and interact with clients, employees, agents, business partners, and others. Paul Hastings recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the "IPP") governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. Paul Hastings’ Internet Privacy Policy can be found at www.paulhastings.com.
CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the Paul Hastings Privacy Office by mail to:
Paul Hastings Privacy Office
Paul Hastings
515 South Flower Street, 25th Floor
Los Angeles, CA 90071
Or by e-mail to Paul Hastings Human Resources
CHANGES TO THIS SAFE HARBOR PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the Paul Hastings web page (www.paulhastings.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.