Privacy Statement

Last updated: 1 May 2024

About this Website Privacy Statement
This website, www.clearyalumni.com, (the “Site”) is provided by Cleary Gottlieb Steen & Hamilton LLP (“Cleary Gottlieb”, the “Firm”, “we”, “us” or “our”) for members of the Firm’s Alumni Network (“you”). Cleary Gottlieb is a New York limited liability partnership and international law firm practising in a number of jurisdictions around the world through affiliated legal entities and branch offices of those entities. Contact details for your local office can be found on the Firm’s website: https://www.clearygottlieb.com/.

This Website Privacy Statement sets out how Cleary Gottlieb collects, uses and discloses your personal data on the Site. Additional information for California residents is set out in the Notice at Collection for California Residents below. For information about how Cleary Gottlieb processes your personal data more generally, please see our Privacy Statement.

What personal data do we process and why?
Your personal data is provided to us directly by you, either on the Site itself or in the Departure Questionnaire which you completed upon leaving the Firm. We may also obtain your personal data from LinkedIn. We use your personal data for the following purposes:

Your “Registration Information"
When you register on the Site we require you to provide the following information so that we may verify your identity and give you access to the Site:

• your username and password (“Login Information”)
• your first and last names
• your preferred email address 
• how you found out about the Alumni Network 
• your Alumni Network role 
• your position at the Firm, and 
• the years you started at and left the Firm.

Your “Login Information”
Once you are registered we use your Login Information each time you access the Site in order to maintain the security of the Site.

Your “Profile Information” 
You may choose to add information to your Profile on the Site. We use your Profile Information for the purposes of enabling other Site users to search for and identify you on the Site and to tailor our communications to you so that we send you communications which we think may be of interest and of relevance to you. Your Profile Information may include all or some of the following information depending on what information you decide to provide:

• Your “Alumni Profile” (visible to other Site users) i.e.:

• your photograph
• your first, middle and last names
• your preferred first name
• your last name at Cleary Gottlieb
• your current location (city)
• your salutation prefix
• your employment status 
• your personal summary 
• your work experience including your current company, position and work address (city, state/province, country only)
• your technical skills
• details of your education including your university/college, field of study, degree type and graduation year
• details of your certifications
• the languages you speak, and
• a link to your LinkedIn profile;

• your “OptionalPrivate Data” (visible to other Site users if you choose to share to your profile) i.e.:
  • your primary email address, and
  • your telephone number;
• your “Private Data”  (visible to you and to the Site administrators only) i.e.:

• your gender
• your alternate email address(es), and
• information about your career at Cleary Gottlieb including your position, the years you started at and left the Firm, the offices you worked in, your affinity groups, your practice areas and your Bar Association memberships. 

Your “User Contributions”
You may communicate with other Site users via the Site’s chat function or by creating, commenting on, or liking a post on the Site. You may also disclose information about yourself in other ways, for example you may choose to submit your “Alumni Story” or an article to us for publishing on the Site. We use your User Contributions for the purposes of enabling our Alumni Network to easily and meaningfully communicate with the Firm and each other about issues of interest. With your prior agreement we may also feature your Alumni Story in our Alumni Spotlight Series on the Firm’s website for the purposes of marketing our Alumni program to our clients. 

Your “Preferences”
We use your chat, email and notification preferences to ensure that we and other Site users communicate with you via the Site according to those preferences.

Information collected via cookies and similar technologies
We automatically collect certain information via cookies and similar technologies (“cookies”) when you visit, use and navigate the Site to distinguish you from other users, provide a better experience when you browse the Site, and improve the Site’s performance and usefulness. The information collected via these cookies does not directly identify you but it may include device and usage information, such as your IP address or other unique identifiers, browser and device characteristics, operating system, country, location and other information about how and when you use the Site.

For details of the information we collect via cookies, and how to give consent, or block and delete cookies on the Site please refer to our Cookie Policy. 

What are the legal bases for this use?
The lawful basis we rely on to process your personal data on the Site is usually legitimate interests. It is in our legitimate interests to provide a functioning Site which enables the Firm to easily and meaningfully keep in touch with members of our Alumni Network and for those members to keep in touch with each other.

In addition, where you have given us your consent to do so, we will use your preferred email address to send you a monthly digest summary email from the Site. You can alter your email preferences or withdraw your consent at any time on the Site by clicking on the User Settings cog in the Contact Info section of your Profile page, navigating to the Email Communications section and unchecking the box. 

To whom will we disclose your personal data and where?
This Site is hosted in the U.S. and maintained on our behalf by EnterpriseJungle, inc. dba EnterpriseAlumni who may, therefore, have incidental access to your personal data. EnterpriseAlumni is bound by appropriate contractual arrangements, including provisions requiring them to: (i) maintain adequate technical and organisational security measures to safeguard personal data; and (ii) process personal data only as instructed by the Firm and for no other purpose. Details of how EnterpriseAlumni handle your personal data, including the sub-processors that they use can be found in EnterpriseAlumni's Privacy Policy. 

Your Alumni Profile and User Contributions will be visible to all other Alumni Network members and Firm personnel who use this Site except for your chats, which will be visible to you and to the person you are chatting with only. 

In some circumstances we may be legally obliged to disclose your personal data. For example, under a court order, or where we cooperate with a Government or regulatory authority handling a complaint or investigation. Where this is the case, we will satisfy ourselves that we have a lawful basis on which to disclose your personal data and document our decision-making before disclosing it. Similarly, we may also disclose your personal data to third parties in the good-faith belief that such action is necessary to take precautions against liability, to comply with various reporting obligations, to protect ourselves and our other users from fraudulent, abusive, or unlawful uses or activity, to protect the security or integrity of the Site or to investigate and defend ourselves against any third-party claims or allegations.

We also may disclose your personal data to other third parties in any way we may describe to you when you provide such information, to fulfil any other purposes for which you provide such information or for any other purpose with your consent or at your direction.

Finally, we may disclose aggregated information about our users, and information that cannot independently be used to identify any individual, without restriction.

How long will we keep your personal data for?

Your chats on the Site are encrypted and stored for six months, unless you and the recipient choose to delete them sooner.

We will keep an unassigned back-up copy of your photograph until our contract with EnterpriseAlumni ends. We will keep all other personal data relating to you on the Site until you ask us to delete it, or until you are no longer registered on the Site. 

What are your rights in relation to your personal data?
Applicable data protection law gives you certain rights over your personal data including: 

• your right of access: you have the right to ask us for a copy of the personal data we hold about you, together with other supplementary information
• your right to rectification: if the information we hold about you is inaccurate, you can ask us to correct it. In some circumstances, you may also be able to ask us to complete incomplete personal data
• your right to erasure: you have the right to ask us to erase your personal data in certain circumstances
• your right to restriction of processing: where you have a particular reason for wanting to do so, you have the right to limit the way in which we use your personal data in certain circumstances 
• your right to object to processing: you have the right to stop us from using your personal data for direct marketing and in certain other circumstances, unless we can show that we have a compelling reason to continue to do so
• your right to data portability: where you have provided your personal data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine-readable format, 
• your right to withdraw consent: where you have consented to us using your personal data, you can withdraw that consent at any time, and
• (in certain jurisdictions) your right to appeal: if we decline to take action in response to your privacy request you may have a right to appeal our decision.

If you would like to exercise any of these rights you can speak to an appropriate member of the Firm’s Risk team by emailing dataprivacy@cgsh.com or by telephoning 833-560-0482. 

If you are not happy with our response you can contact your local supervisory authority (if you are not sure who this is then please contact the Firm by one of the methods above and we will advise you).

Notice at Collection for California Residents

The following disclosures apply solely with respect to personal data processing activities that are subject to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). For information about how Cleary Gottlieb processes your personal data more generally, please see our Privacy Statement.

Categories of personal information and purposes for processing
The categories of personal information we have collected about California residents in the preceding 12 months and the purposes for which we process such data are listed above under “What personal data do we process and why?”.  

Selling and sharing personal information
We do not sell or share personal information to or with third parties nor have we done so in the preceding 12 months.

Retention of your personal information 
The length of time we intend to retain your personal information for is set forth above under “How long will we keep your personal data for?”.

Your rights under the CCPA 
In addition to the rights listed above under “What are your rights in relation to your personal data?”, California residents also have the right to non-discrimination: we cannot deny you access to the Site or otherwise treat you in a discriminatory manner just because you exercised your privacy rights, and the right to appeal: if we decline to take action in response to your privacy request you may have a right to appeal our decision. Note that as we do not do not collect or process sensitive personal information for purposes of inferring characteristics about individuals, nor use or disclose such information to any third parties for any other purposes other than as expressly permitted by the CCPA, we do not offer a right to limit the use or disclosure of such information.

Your privacy rights under the California “Shine the Light” law
We do not disclose personal information obtained through the Site to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

Do not track disclosure  
Third parties such as advertising networks, analytics providers and widget providers may collect information, including personal information, about your online activities over time and across different websites when you access the Site. Currently, various browsers offer a “Do Not Track” option, but there is no standard for how “Do Not Track” should work on commercial websites. Due to lack of such standards, the Site does not respond to “Do Not Track” consumer browser settings.