Privacy Policy for California Residents

This Privacy Policy for California Residents (“California Privacy Policy”) supplements the information contained in Bates White’s Privacy Policy and applies solely to all visitors, users, job applicants, and others who reside in the State of California (“consumers” or “you”). We adopt this California Privacy Policy to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (collectively, the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Privacy Policy. For purposes of this California Privacy Policy, the term “personal information” does not include: (a) information subject to HIPAA or the California Confidentiality of Medical Information Act; (b) deidentified or aggregated consumer information; or (c) publicly available information that (i) has been lawfully made available from government records; (ii) we have reasonable basis to believe has lawfully been made available to the general public by you or from widely distributed media; or (iii) has been made available by a person to whom you disclosed the information unless you restricted such information to a specific audience.

For purposes of clarity, while this California Privacy Policy applies to job applicants; our use and disclosure of employee personal information is governed by separate policy accessible to Bates White employees.

I. Notice at Collection

This Notice at Collection (“Notice”) is to inform you that Bates White is collecting information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("Personal Information"). In particular, the below charts identify which categories of Personal Information and Sensitive Personal Information we have collected within the last twelve (12) months. We retain your information for as long as necessary to achieve the purposes set out in this California Privacy Policy.

Personal Information Category	Examples	Business Purpose
Identifiers	A real name, alias, postal address, Internet Protocol address, email address, education, employment, employment history, and telephone number	Performing services; customer and client relationship management; certain short-term uses; security; marketing or advertising; to communicate with job applicants throughout the hiring process; to assess job applicants’ qualifications, skills, and suitability for the considered job; to verify job applicants’ provided information
Protected classification characteristics under California or federal law.	Sex (including gender, gender identity, gender expression), national origin, to the extent you apply for a job at Bates White and volunteer such information	Performing services; certain short-term uses; security; performing recruiting analytics, data analytics, and benchmarking; to comply with federal and state equal employment opportunity laws
Commercial information.	Records of services performed	Performing services, certain short-term uses, security
Professional or employment-related information.	Current or past job history (only collected to the extent you apply for a job at Bates White)	Certain short-term uses; to communicate with job applicants throughout the hiring process; to assess job applicants’ qualifications, skills, and suitability for the considered job; to verify job applicants’ provided information
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts (only collected to the extent you apply for a job at Bates White)	Certain short-term uses; to communicate with job applicants throughout the hiring process; to assess job applicants’ qualifications, skills, and suitability for the considered job; to verify job applicants’ provided information
Internet or other similar network activity	A person’s browsing history and interactions with our website	Certain short-term uses, security, auditing interactions with our website
Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Performing services, certain short-term uses

Sensitive Personal Information Category	Examples	Business Purpose
Government Identifiers	Social Security Number, driver’s license, state identification card, or passport number (only collected to the extent you are offered a position for a job at Bates White)	To verify job applicants’ provided information and conduct employment background checks
Citizenship or immigration status	Whether a job applicant might require an employer-sponsored visa (only collected to the extent you apply for a job at Bates White)	To assess job applicants’ qualifications, skills, and suitability for the considered job
Racial or ethnic origin	Racial / ethnic origin information (only collected to the extent you apply for a job at Bates White and volunteer such information)	To perform workforce analytics, data analytics, and benchmarking; to comply with federal and state equal employment opportunity laws

Bates White retains Personal Information and Sensitive Personal Information for as long as necessary to provide the services and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data type, the context of our interactions with you or your use of services, actual retention periods can vary significantly.

If you have any questions about this Notice or need to access it in an alternative format due to having a disability, please contact privacy@bateswhite.com.

II. Sources of Personal Information

We obtain the categories of Personal Information we collect from the following categories of sources:

Directly from you. For example, when you communicate with us electronically or in person.
Indirectly from you. For example, from observing your actions on our Website.
Internet cookies.
Data analytics providers.
Job applications and the interview process.

III. Use of Personal Information

We may use the Personal Information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services or to apply for a job with the firm, we will use that Personal Information to respond to your inquiry.
To provide, support, personalize, and develop our Website and services.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Evaluation of job applicants, including communicating with job applicants about their candidacy for employment.
Analyzing our application and recruitment process.
To administer the employment relationship.
To exercise or defend the legal rights of the firm and its employees.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

We collect Sensitive Personal Information only in the context of the hiring process and employment relationship. We do not make any other uses of the Sensitive Personal Information outside of evaluating candidates and our recruiting process and administering the employment relationship.

We will not collect additional categories of Personal Information or Sensitive Personal Information, or use the Personal Information or Sensitive Personal Information we collected for materially different, unrelated, or incompatible purposes, without providing you notice.

IV. Disclosure of Personal Information

We may disclose your Personal Information to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Bates White has disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below. We will not sell the Personal Information or Sensitive Personal Information we collect. We also will not share it with third parties for cross-context behavioral advertising. Because we do not sell or share Personal Information or Sensitive Personal Information, we do not offer users the ability to opt out of such Personal Information sales or sharing.

Personal Information Category	Business Purpose Disclosures	Category of Third-Party Recipients for Business Purpose Disclosures
Identifiers.	To provide the requested services To improve our services To troubleshoot our website To comply with legal requests To process and review job applications Marketing and advertising	Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, HR operations and recruiting/onboarding functions, or business management and development. Representatives of California residents Government agencies
California Customer Records Personal Information categories.	To provide the requested services To improve our services To troubleshoot our website To comply with legal requests Marketing and advertising	Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development. Representatives of California residents Government agencies
Protected classification characteristics under California or federal law.	Process and review job applications	Outside organizations in connection with the hosting of the job applicant portal
Professional or employment-related information.	To process and review job applications	Outside organizations in connection with the hosting of the job applicant portal
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	To process and review job applications	Outside organizations in connection with the hosting of the job applicant portal

Sensitive Personal Information Category	Business Purpose Disclosures	Category of Third-Party Recipients
Government Identifiers	To process and review job applications	Outside organizations in connection with HR operations, recruiting/onboarding functions, and the hosting of the job applicant portal
Citizenship or immigration status	To process and review job applications	Outside organizations in connection with the hosting of the job applicant portal
Racial or ethnic origin (to the extent you apply for a job at Bates White and volunteer such information in your job application)	To process and review job applications	Outside organizations in connection with the hosting of the job applicant portal

V. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

A. Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting or sharing that Personal Information.
The categories of third parties to whom we disclose that Personal Information.
If we shared or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- The categories of Personal Information that we shared about you and the categories of third parties to whom the Personal Information was shared; and
- The categories of Personal Information that we have disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The specific pieces of Personal Information we collected about you (also called a data portability request).

B. Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which it was provided to us.
We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct the same of our service providers, contractors, and, unless impossible or involves disproportionate effort, all third parties to whom we sold or shared the information.

C. Right to Correct

You have the right to request that Bates White correct inaccurate Personal Information that we maintain about you. Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we will review the contested information’s accuracy, considering the totality of the circumstances, and determine if it is more likely than not that the Personal Information we maintain is inaccurate. We will review and consider any documentation you provide to support your correction request and encourage you to make a good faith effort to provide us with all necessary information during the request submission process. If we determine it is more likely than not that the Personal Information is inaccurate, we will correct such information on our systems and instruct all service providers and contractors to whom such Personal Information was disclosed to make the necessary corrections in their respective systems.

Alternatively, we may delete the contested Personal Information instead of correcting it when either:

Deleting it does not negatively impact you, for example, by making it harder for you to obtain a job or any other type of opportunity; or
You consent to deletion.

We may deny your correction request if:

The request conflicts with federal or state law or qualifies for an exception;
Based on the circumstances, the request make compliance impossible or involves disproportionate effort;
We have a good faith, reasonable, and documented belief that the request is fraudulent or abusive;
The request was previously made and denied within the past six months, unless you provide new or additional documentation to prove the contested information is inaccurate; or
We cannot verify your identity to the requisite level.

D. Exercising Your Rights to Know, Delete, or Correct

To exercise your rights described above, please submit a request by either:

Calling us at 1-866-683-7201
Emailing us at privacy@bateswhite.com

Please also note that you may only submit a request to know twice within a 12-month period.

Only you, or someone legally authorized to act on your behalf, may exercise your rights. If you would like to submit a request on behalf of another person as that person’s authorized agent, unless you are the person’s power of attorney, you will be required to: (1) provide proof that the person gave you signed permission to submit the request; and (2) verify your identity with us. You may also make a request on behalf of your child by signing and returning a consent form to us.

Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include:
- For requests to know categories of Personal Information or requests to delete non-sensitive Personal Information pertaining to individuals who are age 13 or older and that pose a low risk of harm, we require:
  - Matching at least two (2) data points from you with the information we hold; and
  - A determination by us that the information matched is reliable for verification purposes.
- For disclosures of specific pieces of Personal Information or deletion of Sensitive Personal Information with a high risk of harm, we require:
  - Matching at least three (3) pieces of Personal Information you provide with information we hold;
  - A determination by us that the information matched is reliable for verification purposes; and
  - A signed declaration under penalty of perjury from you stating that the Personal Information requested is about you.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. You do not need to create an account with us to submit a request to know or delete.

We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.

Note: For information about your opt-out or opt-in rights, see Personal Information Sharing Opt-Out and Opt-In Rights. For information about your right to limit our use of your Sensitive Personal Information, see Right to Limit Our Use of Your Sensitive Personal Information.

E. Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@bateswhite.com. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

F. Right to Limit Our Use of Your Sensitive Personal Information

To the extent that we collect Sensitive Personal Information about you, we only use your Sensitive Personal Information as necessary in order to:

Perform the services reasonably expected by an average consumer who requests such services or by an average job applicant applying for employment;
Help to ensure security and integrity to the extent the use of the Sensitive Personal Information is reasonably necessary and proportionate for these purposes;
Resist malicious, deceptive, fraudulent, or illegal actions directed at Bates White and to prosecute those responsible for those actions;
Ensure the physical safety of natural persons;
Carry out a short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your Sensitive Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside your current interaction with us;
Perform services on our behalf, including maintaining or servicing accounts, providing customer service, verifying client information, processing payments, providing analytic services, or providing similar services on our behalf;
Undertake activities to verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and/or
Collect or process Sensitive Personal Information where such collection or processing is not for the purpose of inferring characteristics about you.

The above-listed uses of Sensitive Personal Information are authorized under California law, and therefore we do not offer consumers the right to limit our use of Sensitive Personal Information. We will ensure you are informed of any additional uses of your Sensitive Personal Information which we may undertake in the future, as well as the process through which you may exercise your right to limit our uses of your Sensitive Personal Information to only those uses listed above.

G. Personal Information Sales and Sharing Opt-Out and Opt-In Rights

We do not sell or share the Personal Information of consumers, and therefore do not offer a process for opting out of Personal Information sales and sharing.

VI. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you services;

Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;

Provide you a different level or quality of services; or

Suggest that you may receive a different price or rate for services or a different level or quality of services.

VII. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@bateswhite.com or call us at 1-866-683-7201.

VIII. Changes to Our California Privacy Policy

We reserve the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

IX. Contact Information

If you have any questions or comments about this California Privacy Policy, the ways in which Bates White collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or if you need to access this California Privacy Policy in an alternative format due to having a disability, please do not hesitate to contact us at:

Phone: 1-866-683-7201
Website: https://www.bateswhite.com/contact.html
Email: privacy@bateswhite.com
Postal Address:
Bates White, LLC
Attn: Legal Department
2001 K Street NW
North Building, Suite 500
Washington, D.C. 20006

Last Updated: November 6, 2025