Privacy Notice

Updated: June 29, 2023

This Privacy Notice explains how Covington collects, uses, shares and otherwise processes your personal data collected on our website, mobile apps and in connection with our blogs, client alerts, recruiting and hiring, and other communication services (the “Services”).  The processing of personal data in connection with client relationships are addressed in engagement agreements between Covington and our clients.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you. Those supplemental notices should be read together with this Privacy Notice.

Information We Collect About You

You may choose to provide information directly to us through various sections of our Services, including, but not limited to:

• Contact information, including name, email address, physical address, and other similar identifiers.
• Professional information, including job title, employment history, and education information.
• Correspondence you send to us, such as when you contact us via email, mail, or phone, or comment on our social media content.

Our systems may also collect information about your browser or mobile device automatically. We may use cookies, web beacons, and similar technologies to help us understand your activity on our Services, as well as for email communications. Data we collect automatically includes the type of web browser or mobile device you use to access our Services, your operating system, your IP address, and general geographical location. For more information on how to manage your cookie preferences, please see our Cookie Policy.

How and Why We Use Your Information

We will use your personal data for the following purposes:

• To provide you information about our Services, new legal and policy developments, news and other relevant information in the industries we serve, and our marketing events. Please note that you may unsubscribe from any commercial email communications you may receive from us by clicking the “unsubscribe” link included in the email.
• To evaluate you as a candidate for employment with our firm.
• To provide alumni communications.
• For analysis to improve this website, our Services and for market research.
• To enforce this policy and respond to verifiable requests.
• For other purposes, with your consent.

Please note that we may use or disclose personal data if we are required by applicable law, regulations, or other legal requirements to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Sharing your Information

We may share your information in the following circumstances: 

• Authorized Third Parties and Service Providers:  We may share your information with entities that provide services to us, including companies that provide web analytics, advertising, email distribution, and other services.  These entities are limited in their ability to use your information for purposes other than providing services for us.
• Other Parties When Required by Law or as Necessary to Protect Our Services:  There may be instances when we disclose your information to legal advisors and public authorities, such as court and law enforcement agencies.
• Other Parties in Connection With a Transfer of Assets:  If we make a sale or transfer of assets, or are otherwise involved in a merger or transfer, we may transfer your information to one or more third parties as part of that transaction.
• Other Parties With Your Consent:  In addition to the sharing described in this privacy notice, we may share information about you with other third parties when you consent to such sharing.

Third-Party Content, Functionality, and Services

Some of the content, functionality, and services on the Services may be provided by third parties that are not affiliated with Covington.  For example, on our blogs we enable you to share certain materials on the Website with others through services such as Facebook and Twitter.  These third parties may collect or receive certain information about your use of the Services, including through the use of cookies, web beacons, and similar technologies.  These entities may collect this information over time and combined with information collected from different websites and online services.  We are not responsible for the privacy practices of these entities.

Children’s Information

We do not knowingly collect or store personally identifiable information about children under the age of 16, unless permitted by law.  If we learn that we have collected personally identifiable information from a child under age 16, we will delete that information from our database.

International Users

This section is supplemental and provides disclosures in addition to those made elsewhere in this Privacy Notice.

Legal Grounds.  We will process your personal data only (1) with your consent; (2) to perform a contract between you and us; (3) to comply with a legal obligation; or (4) where we have a legitimate interest to do so, balancing this interest against your interests and fundamental rights.  These legitimate interests are administrative functions within Covington, marketing activities, and complying with your requests for information.

International Transfers. We may transfer your information to servers located outside your resident jurisdiction, such as when we share information with Covington offices in other countries. These offices may be in countries that offer a lower level of privacy protection than your home country.  We have implemented measures such as standard data protection contractual clauses to ensure that any transferred information remains protected and secure.

Your Privacy Rights

Depending on the jurisdiction in which you live, you may have the following rights subject to the exceptions allowed by law:

• To access your personal information or other information about our data processing practices
• To rectify or update your personal information
• To erase your personal information
• To receive a copy of your personal information
• To object to or restrict the processing of your personal information.
• To lodge a complaint to the supervisory authority for data protection in your country.

To exercise your privacy rights, please contact us at privacy@cov.com or at the address listed at the end of this Privacy Notice. In order to protect your personal information from unauthorized access or deletion, we may ask you to provide additional information so that we can verify your identity. You may also designate an authorized agent to exercise these rights on your behalf in which case we will require documentation attesting that the person acting as your agent is authorized to act on your behalf.

We will not discriminate against you for exercising these rights.

Additional Privacy Rights of California Residents

We do not sell your personal information for money, but there may be occasions where we share your personal information collected through cookies and similar technologies (“cookies”) with advertising partners for the purposes of serving you advertisements based on your activity across other sites and services (“targeted advertising”). To opt out of the sharing of your cookie-based personal information for these targeted advertising purposes, please click the “Do Not Sell or Share My Personal Information” link at the footer of our sites. You may also have the ability to reject or toggle off optional cookies through cookie banners or preference centers on relevant properties. Because our practices differ across different properties, you may need to exercise your choices separately for each property.

We also support the Global Privacy Control ("GPC"), which is a browser-based opt-out preference signal that can communicate your privacy preferences to the websites you visit. For more information on how the GPC works, please visit their website here. Because the GPC is browser-based, note that you should enable the signal separately for each browser and/or device from which you would like to be opted-out

How We Protect Your Information

We use physical, technical and administrative measures to protect your information against loss, theft and unauthorized use, disclosure or modification.  While we strive to protect the information we maintain, we cannot ensure or warrant the security of any information that you transmit to us since no method of data transmission or storage is 100% secure.

Retention Periods

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your personal data, we will consider the following criteria: (i) the amount, nature, and sensitivity of the personal data, (ii) the potential risk of harm from unauthorized use or disclosure, (iii) the purposes for which we process your it and whether we can achieve those purposes through other means, (iv) and any applicable legal requirements.

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

Upon expiration of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.

Changes to this Privacy Notice

We may update this Privacy Notice at any time, and we will make an updated copy of any such Privacy Notice available on our website

Further Information

Should you have any questions about this Privacy Notice or inquiries regarding your personal data rights you can contact us at privacy@cov.com or at the address below.

Data Privacy Officer
Covington & Burling LLP
22 Bishopsgate
London EC2N 4BQ

Cookies, Web Beacons, and Similar Technologies

We — as well as certain third parties that provide content, functionality, or services on the Website — use a variety of technologies to learn more about how people use the Website.  This section provides more information about some of those technologies and how they work. Please find below a list of the cookies we use:

Cookies. Cookies are small text files that websites and other online services use to store information about users on the users’ own computers. Cookies may be used to store a unique identification number tied to your computer so that a website can recognize you as the same user across different visits to the website. You can configure your Internet browser to warn you each time a cookie is being sent or to refuse cookies completely.

We and the third parties that provide content, functionality, or business services on the Website may use cookies to collect information about your browsing activities in order to provide you with more relevant content and promotional materials, on and off the Website, and help us understand your interests and improve the Website.

Web beacons. We, along with our third-party partners, may also use technologies called web beacons that communicate information from your Internet browser to a web server. Web beacons can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the web beacon, the IP address of your computer, and the URL of the web page from which the web beacon was viewed. We and our partners use web beacons for a variety of purposes, including to analyze the use of the Website and in conjunction with cookies to improve the Website and to provide you with more relevant promotion materials.