Privacy Statement

Version date: May 1, 2017

Scope and application
Agreement to this Privacy Statement
Your privacy on the Alumni Site
What information do we gather?
Transfer of your personal data
How do we use your personal data?
With whom will the Alumni Site share personal data?
What are my choices and rights in relation to my personal information?
What about sensitive personal data?
What security precautions are in place to protect the loss, misuse, or alteration of my information?
All About Cookies
Enforcement of this Privacy Statement and Additional Information


Scope and application
This Privacy Statement applies to the Sullivan & Cromwell LLP Alumni Network site (https://alumni.sullcrom.com) hereafter referred to as the "Alumni Site" or the “Site”. The Alumni Site is administered by Conenza, Inc. (“Conenza”) on behalf of Sullivan & Cromwell LLP (“Firm”).


Agreement to this Privacy Statement
The information you provide on this site as a user is used by Firm for the purpose of administering your membership and use of the site as a member of the Sullivan & Cromwell LLP Alumni Network. The Site is controlled and primarily operated by Us in the United States, with certain data center services provided by our third party service provider located in Ireland.  By using this Site, you are consenting to your information being shared with Firm, its divisions and respective affiliates, as well as third-party service providers, such as Conenza, Inc., in processing, collecting, transferring, and otherwise retaining your information and other data you may submit on the Alumni Site.  Your personal information will be collected and used in accordance with the terms of this Privacy Statement and applicable data privacy laws.


Your privacy on the Alumni Site
We want you to feel secure when visiting our Site and are committed to maintaining your privacy online. Please read this Privacy Statement to understand how your personal data will be treated as you use this Site. We may, at our sole discretion, modify, add or remove any or all parts this Privacy Statement from time to time. Such modifications will be effective immediately upon posting of the modified Privacy Statement to the Site.  Your continued use of the Site following the posting of changes to this Privacy Statement will mean that you accept those changes. To update this Privacy Statement, We will post both the changed version and its effective date on the Site. It is your responsibility to check back regularly to review this Privacy Statement and any updates thereto.

The Alumni Site is a private Site available only to current and former lawyers 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 alumni members and do not give out personal data obtained from the Site to anyone.

Please keep in mind that whenever you voluntarily disclose personal information online - in the optional fields in your profile, through email, or in chat areas - that information is accessible to the rest of the members of the Sullivan & Cromwell LLP Alumni Network, and may be made public. Firm is not responsible or liable to you in any way for any misuse of such information by others, including any unsolicited messages you may receive as a result of providing information at this Site.

You have control over contacts you make on the Alumni Site. My Contacts requires two-way confirmation of requests so that when someone requests to be your contact you must confirm that you want to be their contact. The data that your contacts can access is controlled by your privacy settings. You can select to make information in your profile visible to only you, just your contacts or to all users of the Alumni Site.  Regardless of your privacy setting, Firm and Conenza will have access to your profile information. 

Finally, Activity Feed functionality will be added to the Alumni Site in a future release. Activity Feeds highlight activities you take on the Alumni Site such as adding a new contact, submitting a news article, or joining a group. You can select who sees your different types of activities feeds by updating your privacy settings.

What information do we gather?
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.

Any public information regarding your professional experience obtained by Sullivan & Cromwell may be proactively added to your individual profile.  Please see section below entitled “What are my choices and rights in relation to my personal information?” for more information about your rights in relation to your personal information, how to access this information, and how to correct or delete any information we have about you.

Firm also shares a small amount of information about you with Conenza during the registration process in order to verify that you are a Firm alumnus/a. This information may include, but is not limited to, your name, email address, last Firm position, locations, practice group, and law school.

In addition, your user profile offers you the opportunity to provide a wide range of additional information, including postal address, current occupation, industry, education, and personal and business interests. The more information you volunteer (and the more accurate it is), the better we are able to customize your experience. However, please supply only information that is relevant for the stated purposes of this Site. When you complete your profile, you may choose which pieces of information are visible in the directory using the "Privacy" feature in your profile. You may change this at any time by clicking the Edit button in the appropriate section of your profile and then choosing the desired privacy setting in the Privacy feature drop-down list.

We may keep a record of the following types of information:

  • correspondence between you and the Alumni Site;
  • information you post on the Alumni Site, such as, on the chat pages;
  • responses to online surveys that we use for research and quality control purposes; and
  • IP addresses, which are collected indirectly through our website technology and used for system administration purposes.

All pages of the Alumni Site, including pages that collect personal information, include a link to this Privacy Statement.

Transfer of your personal data
For participants in the European Economic Area, we may transfer your personal data from the European Economic Area to countries outside of the European Economic Area, including the United States, in accordance with this policy and applicable laws.   Our service provider, Conenza, has elected to adhere to the EU-U.S. Privacy Shield (“Privacy Shield”) with respect to personal data transferred from the European Economic Area (to learn more, click here).  If third party agents process personal data on Conenza’s behalf in a manner inconsistent with the Privacy Shield Principles, Conenza remains liable unless it proves that it is not responsible for the event giving rise to the damage.  The U.S. Department of Commerce lists the participants in the Privacy Shield framework at https://www.privacyshield.gov/list

If you have a question or complaint related to Conenza’s participation in the Privacy Shield, we encourage you to contact us:

Conenza, Inc.
1932 1st Avenue, Suite 607
Seattle, WA 98101
Attn: Data Privacy
Telephone: 206.792.4247
info@conenza.com

For any complaints related to the Privacy Shield that cannot be resolved directly, Conenza has chosen to cooperate with a panel established by the European Data Protection Authorities (DPAs) for resolving disputes. Please contact Conenza to be directed to the relevant DPA contacts. As further explained in the Privacy Shield Principles, binding arbitration is available to address residual complaints not resolved by other means. Conenza is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

How do we use your personal data?
The Alumni Site will use your personal data for the following purposes:

  • To enable other users to search for and locate you via the directory.
  • Primarily, to provide our users with a customized experience on our Site, including personalization services such as News and Events and interactive communications.
  • To research and analyze our users' demographics, interests and behavior in an aggregated form to better understand and serve our users and improve our Site and its offerings.
  • To contact you periodically with communications about events, publications or employment opportunities with 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 share with other internal Firm systems to contact you with industry relevant information.
  • We may also use data for other purposes, which we would always describe to you when we collect the information.

With whom will the Alumni Site share personal data?
As a global organization, data that Firm collects may be transferred internationally within Firm’s worldwide organization, in accordance with this Privacy Statement, the Terms and Conditions or as otherwise communicated from time to time and in relation to the Sullivan & Cromwell LLP Alumni Site.

The Alumni Site does not sell or rent your personal data. We will not disclose any of the personally identifiable information you provide to this Site to third parties, except:

  • to our service providers, such as auditors, and contractors, including Conenza, who may help develop or maintain this Site,
  • with your prior and informed consent,
  • when required by law or a court of tribunal of competent jurisdiction,
  • to third parties in the event that Firm sells or liquidates all or any part of its business or assets,
  • to business partners or sponsors 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, or
  • in special cases when this is necessary in order to identify, contact or bring legal action against someone who may be violating our Terms and Conditions or may be causing injury to or interference with (either intentionally or unintentionally) someone else's rights or property.

What are my choices and rights in relation to my personal information?
When you register, your name appears in the Alumni Directory and is visible to other registered members of the Sullivan & Cromwell LLP Alumni Network. When you complete your profile following registration, you may choose which pieces of information are visible in the directory using the privacy settings, which are visible in “edit” mode for each section of the profile. You may change this at any time by editing your profile using the "My Profile" function.

You are entitled to know what information we hold about you and to have access to that information. You can access, edit or correct the information in your profile at any time. 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 delete or deactivate your user account, but then you will not be able to access any members-only areas of the Site. If you choose to deactivate your account, we will delete any residual information after a reasonable time, unless otherwise required by law. You can exercise these rights and choices by contacting us at:

Sullivan & Cromwell LLP
125 Broad Street
New York, NY 10004
Telephone: 212-558-4000
alumni@sullcrom.com

What about sensitive personal data?
We do not generally seek to collect sensitive personal data through this Site. In the limited cases where we do seek to 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 life; or criminal record (including information about suspected criminal activities).

What security precautions are in place to protect the loss, misuse, or alteration of my information?
Your user account information is password-protected so that only you, Conenza 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.

We take appropriate steps to maintain the security of personal data collected via the Alumni Site, but no security system is perfect and, as such, we do not guarantee the absolute security of the Site. You should understand that the open nature of the Internet is such that information and personal data may flow over networks connecting you to our systems without security measures and may be accessed and used by people other than those for whom the data is intended.

Our Site may, from time to time, contain links to and from the sites of our partner networks, advertisers and affiliates. The fact that we link to a third party’s website is not an endorsement, authorization or representation of our affiliation with that third party. 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.


All About Cookies
What are cookies and clear GIFs? As part of offering and providing customizable and personalized services, this Site uses cookies and clear GIFs to store and sometimes track information about you. Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a site. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes that cookie. Clear GIFs, also called "web beacons" or "web bugs", are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. In contrast to cookies, which are stored on your hard drive, clear GIFs are embedded invisibly on site pages and are about the size of the period at the end of this sentence. For the purposes of this Privacy Statement, both cookies and clear GIFs are referred to as “cookies.” Cookies are useful because they allow a site to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies.

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? By using our Site, you agree that we can place cookies on your device as explained below. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. 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.

Our use of cookies is solely to collect information which will help us improve the quality of your browsing experience.  We do not use this information for anything other than our own analysis and to improve the quality of your browsing experience.

By continuing to use the Site without changing your browser settings, you agree to our use of cookies as described in this Privacy Statement.


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.
  • 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 Conenza 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. 
     

Enforcement of this Privacy Statement and Additional Information
If you think we are not adhering to the terms of this Privacy Statement, please contact Sullivan & Cromwell at alumni@sullcrom.com.

If we ever change this Privacy Statement, we will post any changes on this page, so that you are always aware of the information that we collect, how we use it, and under what circumstances we disclose it.

If you have any further questions on this Privacy Statement or how your personal data is used in relation to the membership services at this Site, please contact Sullivan & Cromwell at this email address: alumni@sullcrom.com.