Privacy Notice for Beijing and Shanghai Candidates

Effective date: March 2025

Thank you for your interest in Cooley LLP’s representative offices in Beijing or Shanghai (Cooley China). When you apply for a position at Cooley’s China offices (‘we,’ ‘us’ and ‘our’), whether as a partner, employee or contractor, we need to gather personal information from you and other sources. This privacy notice for China Candidates (privacy notice) applies to you if you are located in China. We respect your privacy and are committed to processing your personal information in compliance with applicable laws, including China’s Personal Information Protection Law (PIPL).

Who we are

Cooley LLP is an international legal practice with offices across the United States and with affiliated practices in other jurisdictions (together, ‘Cooley’). The Cooley affiliated practices are separate legal entities that have been established under, and operate in compliance with, applicable local laws, and work together to function as an integrated international law firm. For more information about Cooley, please review the About link on www.cooley.com.

Personal information we collect about you when you apply for a role at Cooley

For the purpose of this privacy notice, personal information means various kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding anonymized information.

When you apply for a job opening with us, we will collect, store and use the following categories of personal information, including sensitive personal information. For the avoidance of doubt, and as defined by statute, sensitive personal information shall include personal information that, once leaked or illegally used, may easily lead to the violation of the dignity of a natural person, or may seriously endanger their personal and property safety. This personal information includes the items highlighted in bold below:

  • Biographical information: Your name, alias, date of birth, gender identity, marital status, citizenship, national origin and/or immigration status.
  • Contact information: Your home address, personal phone number and personal email address.
  • Professional qualifications: Your professional history, employment eligibility, education details, professional designations, licensure information, membership, leadership positions, credentials, professional qualifications and continuing education information.
  • General employment information: Your work location, work status (full time/part time), work history, information for background checks, information related to absence administration, job title, positions held, dates of employment, personnel and disciplinary records, training and learning program participation, promotion history and information needed to evaluate accommodation requests regarding potential disabilities or other health conditions.
  • Audio, electronic and visual information: Your photo and voice recording.

We process your sensitive personal information only to the extent necessary for purposes as described in this privacy notice. We will take reasonable security measures to protect your sensitive personal information consistent with applicable law.

Sources from which we collect your personal information

We collect personal information about you as a candidate from the following sources:

  • You, the candidate.
  • Third parties that we may need to engage to validate information you provide or perform services necessary to our recruiting process, including:
    • Employment recruiting or placement agencies that you may have applied through or may have referred you to us.
    • References and referees that you have named for us to contact.
    • Employers, educational institutions or professional certification organizations you have identified in your CV or application.
    • Where applicable, and to the extent permitted by applicable Chinese laws, background check providers.
  • Publicly available information from online or other public sources.

How we will use your personal information

We process the personal information we collect for the following purposes:

  • Recruitment management – Managing recruitment generally, such as:
    • Operating the careers website we maintain at www.cooley.com/careers or any other site to which this privacy notice is posted (careers site).
    • Recruiting, interviewing and evaluating job candidates.
    • Conducting background checks and other pre-employment screening (where permitted by applicable Chinese laws).
    • Analyzing and improving our application and recruitment processes.
    • Accommodating disabilities or health conditions.
    • Communicating with you regarding your candidacy, opportunities with us or about the careers site, and any changes to applicable terms or policies.
    • Other business operations.
  • Compliance and protection – We may use your personal information to:
    • Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas, investigations or requests from government authorities.
    • Protect our, your or others’ rights to privacy, safety or property (including by making and defending legal claims).
    • Audit our internal processes for compliance with legal and contractual requirements or our internal policies.
    • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  • Analytics – Creating anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes.

Who we share your information with

We may share your personal information, to the extent necessary to fulfill one of the purposes described above, with:

  • Affiliates – Our affiliated entities (e.g., other offices), for purposes consistent with this privacy notice or to operate shared infrastructure, systems and technology.
  • Service providers – Companies that provide us with services to help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
  • Government authorities, law enforcement and others – Government authorities, law enforcement, courts and others as described in the compliance and protection section above.
  • Business transferees – Parties to an actual or prospective business transaction whereby we sell, transfer or otherwise share some or all of our business or assets, including your personal information. We also may disclose your personal data to a successor of Cooley as part or any merger, reorganization or similar transaction, and/or in the event of a bankruptcy or dissolution, in which personal information is transferred to one or more third parties as one of our business assets. The recipient shall comply with this privacy notice when processing your personal information. If the processing methods and purposes of the recipient fall beyond the scope of this privacy notice, such a recipient shall obtain your consent.
  • Professional advisors – Lawyers, immigration advisors and other outside professional advisors.
  • Clients and business partners – Clients, other companies and individuals with whom we do business or are exploring a business relationship, where necessary.

We require that third-party service providers with whom your information is shared take appropriate security measures to protect your personal information, consistent with this privacy notice and applicable laws. We do not affirmatively allow our third-party service providers to use your personal information for their own purposes, and only permit them to process your personal information for the purposes indicated in this privacy notice and in accordance with our instructions.

The details of the recipients of your personal information are set forth in the chart below. Cooley may modify or update this list from time to time:

Recipient name Contact information Processing purpose and method Types of personal information Whether the recipient is located outside the PRC
Cooley LLP servicedesk@cooley.com For the purpose of group human resource management
  • Name
  • Alias
  • Date of birth
  • Gender identity
  • Marital status
  • Citizenship
  • National origin
  • Professional history
  • Photo
  • Home address
  • Personal phone number
  • Personal email address
  • Immigration status
  • Employment eligibility
  • Education details
  • Professional designations
  • Licensure information
  • Membership
  • Leadership positions
  • Credentials
  • Professional qualifications
  • Continuing education information
  • Work location
  • Work status (full time/part time)
  • Work history
  • Information for background checks
  • Information related to absence administration
  • Job title
  • Positions held
  • Dates of employment
  • Personnel and disciplinary records
  • Training and learning program participation
  • Promotion history
  • Information needed to evaluate accommodation requests regarding potential disabilities or other health conditions
 Yes

Retention period for personal information

We will not retain your personal information for longer than is necessary to serve the purposes for which your personal information was collected, and when such personal data are no longer necessary for legal or business purposes. During the time period that we hold your information, we may reach out to you if we consider you for a future position.

Security

We employ a number of reasonable technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. In the event of a confirmed security incident, we will take reasonable remediation actions and notify relevant government authorities and affected users when required by applicable Chinese laws.

International transfer of your personal information

We may transfer your personal information outside of China for necessary purposes as described in the “How we will use your personal information” section of this privacy notice. Whenever we transfer your personal data outside of China, we will adopt lawful transfer mechanisms required under applicable Chinese laws and in accordance with the requirements of the PIPL.

Your rights regarding the personal information we process

Under certain circumstances, and to the extent provided for by applicable Chinese laws, you have the right to access, correct, restrict or object to processing, the right to withdraw consent, and the right to obtain a copy of your personal information retained by us.

If we have not deleted your personal information, you also have the right to request deletion of your personal information under the following circumstances:

  • The purposes of processing have been achieved or cannot be achieved, or your personal information is no longer necessary for achieving the purposes of processing.
  • The retention period has expired.
  • You have withdrawn your consent.
  • Our processing is in violation of applicable Chinese laws or our agreements with you.
  • Other circumstances as provided by applicable Chinese laws.

Contact us

If you want to exercise your rights with respect to any personal information that we process, you may do so by using Cooley’s privacy request form. If you have any questions or complaints about how we process your personal information, please contact privacy@cooley.com. We will respond to your request in a timely manner after verifying your identity.

Changes to this privacy notice

This privacy notice may be amended from time to time. If we make changes to this privacy notice, we will notify you by updating the date of this privacy notice and posting it on our website. If we make any material changes to this privacy notice, where required by applicable Chinese laws, we also will provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through our website.