Version date: March 17, 2022
Scope and application
What personal data do we collect?
How do we use your personal data?
Who has access to your personal data?
How do you safeguard my personal data?
What are my rights?
All about cookies
This Privacy Statement applies to the Sullivan & Cromwell LLP Alumni Network site (https://alumni.sullcrom.com) (“Alumni Site” or “Site”), communications, surveys and other Alumni Program services (“Services"). The Alumni Site is administered by PeoplePath, Inc. (“PeoplePath”) on behalf of Sullivan & Cromwell LLP (“Firm”). The Alumni Site is a private Site available only to current and former lawyers of the Firm, and is designed to maintain a long-term relationship with you and our Firm.
There are many reasons we have an interest in a long-term relationship with you. For example, we may want to rehire you or receive candidate referrals from you, or to do business with you and/or your future employer(s). Also, we hope the Sullivan & Cromwell LLP Alumni Program and this Site will be beneficial to you by making it easy to stay connected with Firm and your former colleagues.
You have the right to object to the processing of personal data, either by opting out of the Alumni Program during registration or at any time after that. For more information about discontinuing the processing of your personal data and your other rights under this Privacy Statement, please see the section below entitled, What are my rights?
If you use the Services, you are consenting to your information being shared with Firm, its respective affiliates, as well as third-party service providers, such as PeoplePath, in processing, collecting, transferring, and otherwise retaining your information and other data you may submit through the usage of the Services. Your personal information will be collected and used only in accordance with the terms of this Privacy Statement (which includes the Cookie Statement) and applicable data privacy laws.
The Alumni Site is a private Site available only to current and former lawyers (“alumni”) of Firm. Please do not give out your username or password to anyone. If you know of an alumnus looking to get access, please ask them to register at the Site. In addition, please respect the privacy of other members and do not give out personal data obtained from the Site to anyone.
Personal data you voluntarily provide us
The Alumni Site collects personal data when you directly give it to us, such as, when you register. During registration and profile set-up, we require that you provide your name and email address. To the extent that Firm has information relevant to the creation of your Alumni Site profile, that information may be automatically added to your profile at this Site. However, this information will not be shared with other members of the Alumni Site until you have accepted this Privacy Statement. When you do accept this Privacy Statement, your name appears in the Directory and is visible to other members of the Alumni Site.
In addition, your user profile offers you the opportunity to provide a wide range of additional information, including photo, postal address, current occupation, industry, education, skills, and personal and business interests. By providing complete and accurate information in your profile, you enable us to customize your experience and help you get the most from our Services. However, please supply only information that is relevant for the stated purposes of this Site.
We also collect personal data in the following situations:
- correspondence between you and the Alumni Site;
- information you post on the Alumni Site, such as, resumes, job applications, event RSVPs, comments on news articles; and
- responses to online surveys or forms that we use for [Firm] feedback, research and product improvement.
Please keep in mind that whenever you voluntarily disclose personal information online - in the optional fields in your profile, through email, or in areas of the Site - that information could be accessible to the rest of the members of the Firm Alumni Network and may be made public. Please do not post or add personal data to your profile or elsewhere on the Site that you would not want to be publicly available.
Information we collect automatically
When you use the Alumni Site, we collect information about your visit and usage of the Alumni Program services. Some of this information is collected using a third-party tool, Google Analytics. That information may include your IP address, your operating system, your browser ID, and other information about how you interacted with the Site. We use this information to improve our services and the user experience as well as network management and security.
Personal data provided by Firm
Firm may share information about you with PeoplePath during the registration process to verify that you are a Firm alumnus/a or current lawyer. This information may include, but is not limited to, your name, email address, last Firm position, locations, practice group, and law school.
What about sensitive personal data?
We do not generally collect sensitive personal data through this Site. In the limited cases where we may collect such data, we will do this in accordance with local data privacy law requirements. If you choose to provide us or members of the Alumni Site with unsolicited sensitive personal data, you consent to our using the data, subject to applicable law as described in this Privacy Statement and in compliance with jurisdiction-specific privacy and data protection regulations therein. The term "sensitive personal data" refers to the various categories of personal data identified by European and other data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent. These categories may include personal identity numbers; racial or ethnic origin; political opinions; religious, philosophical or other similar beliefs; membership in a trade union or profession or trade association; physical or mental health; biometric or genetic data; sexual orientation; or criminal record (including information about suspected criminal activities).
All pages of the Alumni Site, including pages that collect personal information, include a link to this Privacy Statement.
The Alumni Program and related Services will use your personal data for the following purposes:
- Primarily, to provide our users with a customized experience on our Site, including personalization services, such as, contacts, news, events and interactive communications.
- To enable other users to search for and locate you via the directory.
- To research and analyze our users' demographics, interests and behavior to better understand and serve our users and improve our Site and its offerings.
- To contact you periodically with communications about Firm announcements, seminars, events, legal memoranda, publications or employment opportunities with the Firm, affiliates or partners, which we feel might interest you, unless you ask not to be contacted. You will have an opportunity to opt out of receiving further messages.
- To get your feedback and viewpoints through polls and surveys conducted by us and others. You are not obligated to respond to polls and surveys and can choose the information you provide.
- To share with other internal Firm systems for a variety of reasons including to contact you with professionally relevant information.
- To fulfill our legal and regulatory obligations, including reporting obligations and in connection with potential or actual legal or regulatory proceedings or investigations.
- To fulfill our contractual obligations.
- To support and evaluate our personnel.
- To provide and improve our website, including auditing and monitoring its use, including to understand our website audience and demographics and their interests and content preferences.
- To provide information requested by you, including in connection with opting in for our blogs and registering for our account based web channels (e.g., BEAT, DealPortal).
- In connection with the administration of events.
- To analyze whether event invitations and other emails sent by S&C have been successfully sent or have been opened.
- Other uses in the ordinary course of our business that are permissible under applicable law.
We may also use data for other purposes, which we would always describe to you when we collect the information. However, we will not rent or sell your personal data to others.
As a global organization, data that Firm collects may be transferred internationally within Firm’s worldwide organization, in accordance with the Privacy Statement, Terms and Conditions or as otherwise communicated from time to time and in relation to the Firm Alumni Program.
We will not share your personal data with third-parties for marketing purposes. We will share your personal data in the following situations.
- With other users of the Site through the Directory search function and your Profile.You have control over this access through the privacy settings in your Profile. Click on the arrow next to your profile image on the top right-hand side of the home page and click on ‘Privacy’. On the Privacy page, click on the pencil icon and set what other members of the Alumni Network can/cannot view. By default, your privacy settings have been set to allow other members to view your profile details. Regardless of your privacy setting, Firm and PeoplePath will have access to your profile information.
- With our service providers, including PeoplePath for corporate alumni software platform and services and its contractor, Amazon Web Services (AWS), for its data center facilities, which are in Germany.
- With business partners where this is necessary for the purposes related to the Alumni Program, in which case this will be specifically described to you prior to data collection or prior to transferring the data, and you can choose not to allow the transfer by not using that particular service.
- With advisors, including attorneys and accountants, to help us with legal, accounting and security requirements.
- When required to comply with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- In connection with any printed alumni directory or related materials that we prepare from time to time for distribution among alumni and firm lawyers.
General Data Protection Regulation
Under the General Data Protection Regulation, Firm serves as the controller of the personal data you provide us. If at any point you believe your personal data is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer Craig Jones (DPO@sullcrom.com), who will investigate the matter.
Transfers outside the EU
For members in the European Union (EU), we may transfer your personal data from the European Economic Area (EEA) to countries outside of the EEA, including the United States, in accordance with this policy and applicable laws. By submitting your personal data, you are agreeing to this transfer, storing and processing of the information. For example, if a non-EU user does a Directory search or views your profile, your personal data will, in effect, be transferred outside the EU. We have no control over another user’s usage of your personal data.
Additionally, we may transfer your information to a service provider and/or Firm’s system/server located outside of the EEA. In this case, the transfer, data protection and privacy measures in place are in accordance with the General Data Protection Regulation, as well as, other laws and regulations in the member state in which you are located.
PeoplePath participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from EU member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome. A list of Privacy Shield participants is maintained by the Department of Commerce and is available at: https://www.privacyshield.gov/list.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the appropriate EU Data Protection Authority (DPA) free of charge. A list of DPAs can be found here. Under certain conditions, more fully described on the Privacy Shield website, https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
Your user account information is password-protected so that only you, PeoplePath and Firm have access to this personal information. Do not divulge your password to anyone. Also remember to sign out of your account and close your browser window when you have finished using the Site, particularly if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.
Our Site may, from time to time, contain links to other sites. If you follow a link to any of these sites, please note that these sites have their own privacy statements and that we do not accept any responsibility or liability for these statements or sites. Please check these privacy statements before you submit any personal data to these sites.
You are entitled to know what personal data we process and store about you and to have access to that information. You can access, edit or correct the information in your profile at any time. Log in to the Alumni Site and click on Profile. If you have forgotten your password, click on the Forgot Password link and we will send an email to your primary email address.
You can choose not to receive any communications from us about events or publications we feel might be of interest to you. Finally, you can ask us to deactivate, delete or transfer your personal data, but then you may not be able to access any members-only areas of the Site. If you choose to delete or transfer your account, we will delete any residual information after 60 days, unless otherwise required by law.
We will retain your personal data only as long as you have a user account on the Alumni Site. If you decide to delete your user account, we will retain your data for 60 days before permanently deleting the data, unless legally required to retain the information for a longer period of time.
You can exercise any of these rights or ask any questions by contacting us at:
Sullivan & Cromwell LLP
125 Broad Street
New York, NY 10004
Rights regarding personal information for California residents
Pursuant to the California Consumer Privacy Act (CCPA), California residents receive certain rights with respect to their personal information, as described below. These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA. California residents have the right not to receive discriminatory treatment from us for the exercise of the privacy rights conferred by the CCPA.
Right to know about personal information collected, disclosed, or sold
Each California resident has the right to request, subject to certain exceptions described in the CCPA, that we disclose to that resident:
- the categories of personal information we have collected about them,
- the categories of sources from which the personal information is collected,
- the business or commercial purpose for collecting or selling the personal information,
- the categories of third parties with whom we have shared the personal information, and
- the specific pieces of personal information we have collected about them (collectively, a “Request to Know”).
To make such a Request to Know, you can either call us at our toll free number (1-888-558-1505), or fill out our request form here.
In the past twelve months we have collected, and in the future we will continue to collect, the categories of personal information cited in the section entitled “What personal data do we collect?” above. For clarity, this information includes name, alias, postal address, online identifier, Internet Protocol address, email address, SSN, driver’s license number, passport number, signature, physical characteristics or description, telephone number, state ID card number, employment, employment history, bank account number, characteristics of protected classifications under CA or federal law, including race, color, national origin, gender, disability, age (40 and older), citizenship status, gender identity, sexual orientation, marital status, military or veteran status, and political activities or affiliations, Internet or other electronic network activity information (including, but not limited to, information regarding your interaction with our website), geolocation data, professional or employment-related information, and education information. We collect this information from the sources described in the section entitled “What personal data do we collect?” above, use this information as described in the section entitled “How do we use your personal data?” above, and share this information with the third parties as described in the section entitled “Who has access to your personal data?” above.
We do not sell your personal information.
Right to request deletion of personal information
Each California resident has the right to request the deletion of their personal information that we collect or maintain (a “Request to Delete”), subject to certain exceptions set forth in the CCPA. To make such a Request to Delete, you can either call us at our toll free number (1-888-558-1505), or fill out our request form here.
Process for verifying requests of California residents
In order to protect your privacy and security, prior to completing any Request to Know or Request to Delete that you may submit, we must verify your identity. We will verify your identity by asking you to provide certain data that we have already collected from you to confirm that they match our records. In certain instances, additional verification steps may be required.
California residents have the right to designate an authorized agent to make a request under the CCPA on their behalf. Prior to completing a request made by such an authorized agent, we require that you provide your authorized agent with written permission to submit such a request and require that you or your authorized agent provide us with a copy of such written permission. Additionally, we require that you verify your identity pursuant to the procedure described above.
What are cookies and clear GIFs?
Cookies do a lot of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience.
The cookies used on this Site have been categorized on the basis of the categories found in the ICC UK Cookie guide issued in April 2012. A list of all the cookies used on this Site by category is set out below.
What if I don’t want cookies? A cookie banner is displayed when you first access the site. You may either accept the cookies or reject all but essential cookies. Essential cookies include cookies that persist the life of your current logged in session and are required for the site to function.
For more information on managing cookies see www.allaboutcookies.org/manage-cookies/. Please note that current “Do Not Track” initiatives are not recognized by our Site.
Please bear in mind that deleting and blocking cookies will have an impact on your user experience as parts of the Site may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon you visit our Site, even if you have previously deleted our cookies.
Turning off cookies will also prevent any web beacons from tracking your user activity on our Site. The web beacon will still account for an anonymous visit, but your unique information will not be recorded.
What cookies do we use on the Alumni Site?
- Strictly necessary cookies – These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for cannot be provided. Examples of strictly necessary cookies include session-based cookies which are deleted when you leave the site that maintain the state of your current activities and persistent cookies (cookies that remain on your machine between visits) for functionality such as “keep me logged in” or remembering your preferred language.
- Performance cookies - These cookies collect information about how visitors use a site; for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a site works. Performance cookies used by the Site include Google analytics tracking cookies, used to track analytics of site use, including pages viewed and whether the individual is a new or repeat visitor.
- Functionality cookies - These cookies allow a site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a site may be able to provide you with local information or news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of the Site’s pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. We may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile. In some cases, we pass this information on to others within Firm for marketing or analysis purposes. In most cases, we will not be able to track individuals by name. Only if a user is a registered user, will we associate the cookie information with a named individual. These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the internet outside our Site. Functionality cookies used by the Site include PeoplePath tracking cookies to authenticate the user by log-in details and remember language selection, and Social login cookies to remember when someone has previously used social log-in.
- Targeting cookies - These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the site operator’s permission. They remember that you have visited a site and this information is shared with other organizations such as advertisers. Quite often they will be linked to site functionality provided by the other organization.