PRIVACY POLICY

July 25, 2025

• I.    INTRODUCTION
  Cadwalader, Wickersham & Taft LLP (“Cadwalader”, “we” or the “Firm”) is committed to protecting individuals’ privacy rights, which is why the Firm has developed and implemented this Policy.  
  
  This Policy explains:
  •    the types of personal information we collect about you;
  •    the means by which we obtain your personal information;
  •    the ways in which we use your personal information;
  •    the basis on which we use your personal information;
  •    whom we share your personal information with;
  •    the length of time for which we keep your personal information;
  •    how we protect your personal information; and
  •    where and why we transfer your personal information outside of the EU.
  
  We may collect your personal information in your capacity as a client, potential client, alumnus, job applicant and/or as a visitor or subscriber to our website(s), including www.cadwalader.com, Fund Finance Friday Newsletter www.cadwalader.com/fund-finance-friday, Ref News and Views Newsletter, www.cadwalader.com/ref-news-views, Brass Tax Newsletter www.cadwalader.com/brass-tax, the alumni website www.cadwaladeralumni.com, State Attorney General insider, and www.cadwalader.com/state-attorney-general-insider (collectively, the “Cadwalader Sites”).
  
  By providing your personal data to us (whether via one of the Cadwalader Sites, by email, in person or over the phone), you agree to the processing set out in this Privacy Policy.
  
  II.    DATA CONTROLLER AND RESPONSIBLE OFFICER
  Cadwalader, a New York limited liability partnership located at 200 Liberty Street, New York, NY 10281, is the Data Controller responsible for the implementation of this Policy.
  
  Should you have any questions about this Policy or how Cadwalader handles your personal information, please contact the Office of the General Counsel, or Jillian Padley, Associate General Counsel, at privacy@cwt.com.
  
  III.    THE TYPES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU
  We may collect your personal information when conducting our business, including when you contact us, seek information from us, use one of our websites or engage us to provide our legal or other services.  We may also collect your personal information for recruiting purposes.
  
  The personal information that we process includes:
  •    personal identifying information, such as your name (including your name prefix or title);
  •    employment information, including your employer, your title and your job description;
  •    background check information to enable us to assess a prospective employee’s suitability for employment;
  •    contact details, including your postal address, email address and telephone numbers;
  •    personal information required to satisfy legal requirements, such as your anti-money laundering requirements (for example, passport details);
  •    financial information (for example, your bank account details);
  •    technical information (for example, the number of visits you make to our websites, or your receipt and use of materials and communications we send to you electronically);
  •    personal information you provide to us in advance of and during meetings and events, including your physical access and dietary requirements;
  •    personal information we receive by or on behalf of our clients, or created by us when providing services to our clients, which may include special categories of data; and
  •    in response to public health emergencies such as the Covid-19 pandemic (or similar health crisis) we may request health data (including for this purpose vaccination status, Covid test results or information about any recent travel you may have undertaken)  to comply with our health and safety obligations and support our  prevention measures, including in relation to access to our premises. Any such processing will be undertaken in line with relevant, government and Information Commissioner guidance and where there is a clear lawful basis to process such data (see below);
  •    any other information relating to you that you may provide to us.
  
  IV.    HOW WE RECEIVE YOUR PERSONAL INFORMATION
  We come into possession of your personal information in many ways, including:
  •    during the monitoring of our technology, including the Cadwalader Sites and email communications sent to and from Cadwalader;
  •    as part of our business onboarding processes and during the course of our providing legal services;
  •    when you provide information to us, or during your interactions with us directly, including face to face interactions with our staff and online interactions using the Cadwalader Sites or email; and
  •    from third-party sources (including, for example, LinkedIn and other social media).
  
  Please note: This Privacy Policy does not apply to, and we are not responsible for, any third party websites which may be accessible through links from this website. If you follow a link to any of these third party websites, they will have their own privacy policies and you will need to check these policies before you submit any personal data to such third party websites.
  
  V.    HOW WE USE YOUR PERSONAL INFORMATION
  We collect and process your personal information in a variety of ways, including when you use the Cadwalader Sites and when we provide our services to you.  When we collect and process personal information, we do this:
  •    to manage and administer our relationship with clients, vendors and other third parties in the conduct of Cadwalader’s business;
  •    to market our services, including sending publications and the details of events to our clients and friends;
  •    to conduct recruitment;
  •    to administer our websites, including our monitoring of their use;
  •    to deliver and enhance our services, which may include handling personal information on behalf of our clients;
  •    to make available information requested by you; and
  •    to meet any of our legal, regulatory and risk management obligations.
  
  We may use your personal data in the following ways identified below. In each case, we note potential grounds on which we may rely to use your personal data (see also Section 6 (“The Bases On Which We Use Your Personal Information”)); other grounds may also apply. 
  
  A.    LEGAL AND OTHER SERVICES
  When we provide services to our clients, including to carry out our obligations arising from any agreements entered into with clients, we may collect, develop, retain and use personal information.
  
  We process personal identification information in order to process new clients and conduct our business acceptance processes, including anti-money laundering, conflict, reputational and financial checks, and as part of our finance, administration and marketing processes. 
  
  We will process personal information that our clients, or third parties on behalf of our clients, provide to us for the purposes of providing our services.  To the extent reasonably necessary in connection with our services, we may need to share personal information with third parties.  Please also see sections 7 (“Who We Share Your Personal Information With”) and 9 (“Transferring Your Personal Information to Other Countries”) below.
  
  Legal grounds: contract performance, legitimate business purposes, consent. 
  
  B.    MARKETING AND OTHER EMAILS
  If you receive our marketing materials, we may use your personal information to try to understand:
  •    whether you open our emails or other materials, including Clients & Friends Memos, either by downloading images in the emails or clicking links;
  •    whether you click on the web links, unsubscribe links or event RSVP links included in our emails and marketing materials;
  •    whether and how you visit our websites after you click on links we have shared with you, both immediately and on future visits.  We do this by using software that places a cookie on your device that tracks this activity and records it against your email address.  Please see our Cookie Policies, which are posted on our websites, for more information on how to manage and remove cookies.  Refusal of this cookie will not affect your experience on the Cadwalader Sites. 
  
  We may also use a relationship management tool, where permitted by applicable local law, to assess the strength of the relationship between individuals in Cadwalader and our clients or potential clients based on the frequency of email contact between them.  We use that information in order to assess, analyze and improve the services that we provide.
  
  If you receive marketing communications from us and no longer wish to do so, you may unsubscribe at any time by emailing privacy@cwt.com.
  Legal grounds: Legitimate business purposes, consent. 
  
  C.    MEETINGS, EVENTS AND SEMINARS
  When you attend meetings and events organized by Cadwalader or one of its business partners or contractors, we may collect and process personal information about you in relation to your attendance, including your contact information, name and employer.  We also may collect special categories of personal information, including dietary requirements, allergies or access requirements, so that we can appropriately cater to your needs and meet any other legal or regulatory obligations we may have.  We may share your information with our business partners and contractors who are involved in organizing or hosting the relevant events.
  Legal grounds: Legitimate business purposes, consent.
  
  D.    USING CADWALADER'S WEBSITES
  When you use the Cadwalader Sites, you may be asked to provide us with personal information; for example, when you sign up to our Cabinet news resource, you will be asked to provide your name and contact information.  When you provide us with personal information in this way, we only use it for the purposes stated to you at the time we collect that information.
  
  We also use cookies on the Cadwalader Sites.  Please see our Cookie Policies, which are posted on our websites, for more information on how to manage and remove cookies.
  
  Legal grounds: Contract performance, legitimate business purposes, consent.
  
  E.    RECRUITMENT PURPOSES
  When you apply for employment with us, you may be asked to provide us with personal information to enable us to process applications for employment and to assess your suitability for any position for which you may apply at Cadwalader.
  
  Legal grounds: Contract performance, legitimate business purposes, consent.   
  
  F.   FULFILL LEGAL, REGULATORY OR RISK MANAGEMENT OBLIGATIONS
  You may be asked to provide us with personal information so that we can comply with our legal obligations (e.g., performing client due diligence/”know your client”, anti-money laundering, anti-bribery, sanctions or reputational risk screening, identifying conflicts of interests); for the prevention of fraud and/or other relevant background checks as may be required by applicable law and regulation and best practice at any given time (if false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them); to enforce our legal rights (e.g., to recover any payments due to us), to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties.
  
  Legal grounds: Legal obligation, legal claims, legitimate business purposes. Where we process special categories of personal data we may also rely on substantial public interest (e.g., prevention or detection of crime) or legal claims.
  
  VI.    THE BASES ON WHICH WE USE YOUR PERSONAL INFORMATION
  We use your personal information on the following bases:
  •    Contractual performance: the performance of contractual obligations, including the provision of legal and other professional services, where your information is necessary to enter into or perform our contract with you;
  •    Legitimate business purposes: where we use your information to achieve one or more legitimate business purposes, which are described more fully above in section 5 (“How We Use Your Personal Information”);
  •    Consent: your explicit consent;
  •    Legal obligation: in order to comply with legal and regulatory obligations;
  •    Legal claims: the establishment, exercise or defense of legal claims and proceedings; and
  •    Public interest: for the purposes of substantial public interest, including in relation to public health.
  
  VII.    WHO WE SHARE YOUR PERSONAL INFORMATION WITH
  We are a law firm headquartered in New York, with offices in Charlotte, Washington D.C., London and Dublin.  Information that you provide to us may be shared with and processed by any of the Cadwalader offices. 
  
  If Cadwalader’s business structure changes in the future, we may transfer your information to new Cadwalader offices or to third parties for the purpose of carrying out Cadwalader’s business.
  
  We may share your personal information with third parties in accordance with the contractual arrangements we have put in place with them, including with:
  •    our professional advisers and auditors;
  •    third party suppliers we engage to conduct certain services on our behalf, including  translators and document reviewers, meeting planners, event organizers and IT service providers; and
  •    other third parties we engage when providing services to our clients, including local counsel, barristers, experts, data room providers, transcript and case management service providers.  
  
  We also may share personal information with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies where such disclosure is necessary to comply with legal or regulatory requirements. At times this may include the disclosure of health data to public authorities, for example for the purposes of the Covid-19 pandemic. Unless we are restricted from doing so by law, we will use reasonable endeavors to notify you before we make any such disclosure.  
  
  We do not allow personal information to be made commercially available to any third party unless we have first obtained your prior permission. 

VIII.    HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We retain your personal information for as long as necessary to comply with our legal, regulatory and professional obligations, and any other permitted purposes.  If your personal data is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. Our retention periods are also based on our business needs and good practice.

IX.    TRANSFERRING YOUR PERSONAL INFORMATION TO OTHER COUNTRIES
When providing our services, we may need to transfer your personal information outside of the country in which you are located for the purposes set out in this Policy.  This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) or UK to outside the EEA or UK, or from outside the EEA or UK to a location within the EEA or UK.  Please see section 7 for more detail on how the information may be shared with Cadwalader offices and third party service providers. 

The level of information protection in countries outside the EEA or UK may be less than that which is offered within the EEA or UK.  Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.  Where our third party service providers process personal information outside the EEA in the course of providing services to us, appropriate measures, usually standard contractual clauses, will be included in our written agreement for the service provision.

X.    HOW WE PROTECT YOUR PERSONAL INFORMATION
While no data transmission can be guaranteed to be secured from intrusion, consistent with applicable data protection laws, we utilize technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration or destruction.

Cadwalader holds the internationally recognized security standard BS ISO/IEC 27001:2013 in respect of its document management and email systems and the supporting infrastructure for Cadwalader’s offices globally.  This is an independently verified certification that information security is managed in line with international best practices.

XI.    RIGHTS OF EUROPEAN UNION RESIDENTS REGARDING YOUR PERSONAL INFORMATION
Pursuant to the European Union’s General Data Protection Regulation and other applicable data protection laws, data subjects within the European Union and United Kingdom have certain rights that we are obliged to protect.

You are entitled to request details of the information we hold about you and how we process it. 

In certain circumstances, you also may have the right to: 
•    have the information that we hold about you rectified or deleted;
•    restrict our processing of that information;
•    request that we stop unauthorized transfers of your personal information to a third party; 
•    where processing is based on consent, you may withdraw your consent so that we stop that particular processing;
•    where processing is based on a legitimate business purpose, you may object to any processing based on that legitimate purpose unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
•    request that we do not transfer information relating to you to another organization.  

You also may have the right to lodge a complaint in relation to Cadwalader’s processing of your personal information with a local supervisory authority. 

Where you object to our processing of your personal information, or where you withdraw consent previously given, we may not be able to achieve the purposes set out above in section 5 or you may not be able to use our services and products.

Where you object to our processing of your personal information, or where you withdraw consent previously given, it is important to understand that we may be able to continue to process your personal information to the extent required or otherwise permitted by law, particularly in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations. 

Please inform us of any changes to your information by emailing us at privacy@cwt.com so that we can keep your information up to date.

XII.    MAKING A COMPLAINT
We strive to meet the highest standards when handling your personal information and deal seriously with any complaints we receive.
If you think that our collection or use of information is unfair, misleading or inappropriate, please bring it to our attention by contacting our General Counsel whose details are set out in section 2 (“Data Controller and Responsible Officer”) of this Policy.  We also welcome suggestions for improving our procedures.

If you are located within the UK or any European Union member state and are not content with our response to your complaint, you also have the right to complain to your local data protection authority in the jurisdiction of the office in which services are being provided.  If services are being provided in the UK, then you may request that the UK Information Commissioner’s Office investigate the matter further by contacting:

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone:  (UK) 0303 123 1113 / (abroad) 44 1625 545 700.

XIII.    CHANGES TO OUR PRIVACY POLICY
Cadwalader reserves the right to change this Policy from time to time as needed.