Introduction
This Privacy Policy (“Policy”) explains how Pearl Cohen Zedek Latzer Baratz (“Pearl Cohen”, the “Firm” “we”, “us”, “our”) collects and uses your information when you engage to receive legal services from us, express interest in our legal services, or visit our one of our offices.
Pearl Cohen is an international law firm with offices in Israel (Tel Aviv), the United States (New York, Los Angeles, Boston), and the United Kingdom (London).
Our legal services are not directed at individuals under the age of 18. We do not knowingly collect information from children under the age of 18.
This Policy may be amended from time to time. If the nature of the change necessitates, we will proactively notify you of the change using your contact information we have on file. We will also post the updated Policy on at the same webpage a reasonable time in advance of the effective date of the change.
Contact us
If you have any questions, comments, or concerns regarding this Policy or our processing of your personal information, please contact us at [email protected].
What we collect and why
| Scenario | Purposes | Categories of information processed |
| Performing mandatory compliance checks with respect to prospective and existing clients (such as a ‘know you client’ (KYC) procedure) | Complying with laws and regulations applicable to us, such as anti-money laundering laws. Complying with internal firm guidelines and professional codes of conduct. |
The following information about individuals who are prospective or actual clients, or individuals who are shareholders of prospective or actual clients: full name, ID number or passport details, photocopy of ID or passport, date of birth, gender, physical address, residency, information relating to your profession, familial relationship with governmental officials, and other information required by law.
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| Legal services | Providing legal repesentation and advice |
Name, position and contact information of you as the individual who is our client, or of you as a representative of the organization who is our client. Any information about you or other individuals that is related to your legal affairs, such as names of individuals relating to the legal advice requested, contact information of individuals, description of events or financial information regarding which you seek legal advice, ownership, inventorship or authorship of intellectual property rights, shares of stock and share options, payroll and benefit information, which are necessary, for example for employment and tax advice. |
| Payments | Collecting payments for legal services | Payment details. |
| Visiting our offices | Safety and security of the firm, its staff, and visitors | When you visit our offices, footage of you will be recorded by our security cameras. |
| Contacting us with an inquiry through our email or through our online contact form, or registering to events we organize or sponsor | Responding to your inquiry, event registration request, promoting the Firm’s business development. |
Full name, company name, position, email address, the subject of your inquiry and the text of your message. You may also optionally provide your phone number.
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| Subscribing to our newsletters | Providing you with the newsletter you requested, such as legal updates and conference invitation. | Full name, company name and email address. You may also optionally provide your position in the company. |
You do not have a legal obligation to provide the information that we request. However, if you choose not to provide this information to us, we may not be able to provide legal services to you, respond to your inquiry or registration request, and provide you with our newsletter.
Methods and sources for collecting your personal information
We collect the personal information from several sources:
- Directly from you.
- From others who provide information about you, where that information relates to legal advice sought from us.
- Our service providers help us to provide you with legal services.
- From other law firms who represent counterparties.
- From other law firms with whom we work to represent the client.
- From publicly available sources, such as court decisions, government-agency directories, etc.
Sharing your personal information
We will not share your information with third parties, except in the events listed below or when you provide us with your explicit and informed consent.
When we share client information with third parties, we do so respecting attorney-client privilege and client-confidential information.
| Scenario | Purposes | Third parties involved |
| We will share your information with our service providers who assist us with the internal operations of the Firm’s business, and with the provision of legal services to you. These providers are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes. | Operating the Firm’s business in providing legal services. |
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| We will share your information with other law firms as necessary to represent the client in their legal affairs and provide legal advice to the client | Representing and advising the client. |
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| If you violated any applicable law while engaging with us | Responding to, handling, and mitigating suspected violations of law that could impact the Firm. | Competent authorities, legal counsels, and advisors. |
| If we are required to disclose your information to a judicial, governmental, or regulatory authority | Complying with legal, judicial and ethical requirements from a competent authority. | Competent authorities. |
| If the Firm’s operations are organized within a different framework, or through another legal structure or entity | Enabling a structural change in the Firm. | The target entity of the merger or acquisition, legal counsels, and advisors. |
Data retention and security
We retain your information so long as you are a client, and thereafter as needed for record-keeping purposes
We will retain your information so long as you are an active client of our firm. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish, and defend legal claims and enforce our agreements.
We implement measures to secure your information
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, there is no guarantee that it will be immune from information security risks.
Additional information for individuals in Israel
This segment applies to you if you are in the capacity of an individual client of the Firm.
When you engage the Firm to receive legal representation or legal advice, you also see your consent to this Policy. Your consent to this Policy is at your discretion and choice. However, if you do not consent to this Policy, you will not be able to engage the Firm and receive legal representation or legal advice from the Firm.
You have a right to obtain access to the information the Firm has about you. If you reviewed the information the Firm has about you and found it to be incorrect, incomplete, unclear, or outdated, you may ask that the Firm correct the information or delete it. Your right to access, correct and delete is subject to exceptions provided in the law. For example, if the information about you is a client’s privileged information, we will not provide you with access to the information we have about you.
By consenting to this Policy, you also consent to the Firm transferring your personal information across international borders to recipients described in the chapter above titled “Sharing your personal information”. These recipients are at times located in countries outside Israel,
Additional information for individuals in the EU or UK
Controllers
The data controllers of the personal data we collect and process when you engage with us to receive legal services are the following:
Pearl Cohen Zedek Latzer Baratz, an Israeli general partnership. Azrieli Sarona Tower- 53rd floor, 121 Menachem Begin Rd. Tel-Aviv, 6701203, Israel. Tel. +972-3-303-9000. Fax. +972-3-303-9001. Email: [email protected]
Pearl Cohen Zedek Latzer Baratz LLP, a Delaware limited liability partnership doing business in New York, Massachusetts and California. Times Square Tower, 7 Times Square, New York, NY 10036. Tel. 646-878-0800. Fax. 646-878-0801. Email: [email protected]
Pearl Cohen Zedek Latzer Baratz UK LLP, a limited liability partnership registered in England and Wales. The Gridiron Building, One Pancras Square, London, N1C 4AG, UK. Tel. +44(0)-203-714-4980. Fax. +44-203-031-1298. Email: [email protected]
International data transfers
To facilitate the processing of your information, we transfer your information to countries outside the EU and the UK to other countries including Israel and the United States.
Legal basis for processing your personal data
| Purpose or Scenario | Legal Basis |
| Performing mandatory compliance checks with respect to prospective and existing clients (such as a ‘know you client’ procedure) | Compliance with legal obligations in UK law imposed on us.
Where the legal requirements are not within UK law, out legal basis is our Legitimate interest in complying with mandatory |
| Providing legal services | Necessity for the performance of our legal services contract with our client who is an individual. If our client is not an individual, our legal basis is our legitimate interests in performing our professional duty of loyalty and duty to prudently represent clients. |
| Collecting payment for legal services | Necessity for the performance of our legal services contract with our client who is an individual. If our client is not an individual, our legal basis is our legitimate business interests in receiving payments due for our legal services. |
| Capturing footage of you through security cameras when you visit our offices | Our legitimate interest in the ongoing operation, safety and security of the Firm, our workforce and visitors. |
| Responding to your inquiry or event registration request | Our legitimate interests in the Firm’s business development, responding to your inquiry or event registration request. |
| Subscribing to our newsletters | Our legitimate interests in the Firm’s business development. |
| Responding to, handling, and mitigating suspected violations of law impacting the Firm | Legitimate interests in defending and enforcing violations and breaches that are harmful to the Firm. |
| Complying with a binding request from a competent authority | Compliance with legal obligations in UK law imposed on us.
Where the binding request is not within UK law, our legal basis is our legitimate interests in complying with mandatory legal |
| Enabling a structural change in the operation of our Firm’s business | Legitimate interests in our business continuity. |
Data subject rights
If you are in the EU or the UK, you have the following rights under the GDPR:
Right to Access and receive a copy of your personal information that we process. Your right to access data about you will be restricted if this is required to protect the rights and freedoms of others – for example, if the personal data about you is a client’s privileged information.
Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.
Right to Data Portability, that is, to receive the personal information that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another person or entity. Where technically feasible, you have the right to have your personal information transmitted directly from us to the person or entity you designate.
Right to Object to our processing of your personal information based on our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to process such personal information for the establishment, exercise, or defense of legal claims.
Right to Restrict us from processing your personal information (except for storing it): (a) if you contest the accuracy of the personal information (in which case the restriction applies only for a period enabling us to determine the accuracy of the personal information); (b) if the processing is unlawful and you prefer to restrict the processing of the personal information rather than requiring the deletion of such data by us; (c) if we no longer need the personal information for the purposes outlined in this Policy, but you require the personal information to establish, exercise or defend legal claims; or (d) if you object to our processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).
Right to be Forgotten. Under certain circumstances, such as when you object to our processing of your personal information based on our legitimate interest and there are no overriding legitimate grounds for the processing, you have the right to ask us to erase your personal information. However, notwithstanding such a request, we may still process your personal information if it is necessary to comply with our legal obligations, or for the establishment, exercise, or defense of legal claims. If you wish to exercise any of these rights, please contact us through the channels listed in this Policy.
When you contact us, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
If you are in the UK, you can lodge a complaint to the Information Commissioner’s Office (ICO) pursuant to the instructions provided here.
Additional information for individuals in the United States
If you are an individual residing in the United States, we provide you with the following information pursuant to the applicable state privacy laws.
We do not sell your personal information and have not done so in the past 12 months. We do not share your personal information for cross-context behavioural advertising.
Below are the categories of personal information we have collected over the past 12 months, and the business purposes for its collection.
| Categories of personal information | Specific types of personal information collected | Business Purposes for which the information is used |
| Identifiers | Full name, email address, IP address, postal address.
Sensitive information: photocopy of passport or ID. Names of individuals relating to the legal advice requested. |
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| Other personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual |
Phone Number, residence.
ID number, date of birth, familial relationship with governmental Contact information of individuals relating to the legal advice requested. Any other information concerning your legal affairs, which may include sensitive information (e.g., your email communications with third parties). |
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| Characteristics of protected classifications under law |
Gender | |
| Commercial information | Payment information.
Description of events or financial information regarding which you The content of an inquiry you send us. |
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| Professional or employment-related information | Name of your company name, your position. Description of events regarding which you seek legal advice. |
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| Audio and visual information | Footage of you recorded through our offices’ security cameras. | |
Disclosures to third parties
The chart below explains the personal information we disclosed for a business purpose to third parties in the preceding 12 months.
When we share client information with third parties, we do so respecting attorney-client privilege and client-confidential information.
| Categories of personal information | Categories of third parties to whom we disclose your information and the reason for the disclosure |
| Identifiers
Other personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual. Characteristics of protected classifications under law. Commercial information. Professional or employment-related information. Audio and visual information. |
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Your rights under U.S. State privacy laws
Knowing the personal information we collect about you
You have the right to know (provided we successfully verify your identity):
- The categories of personal information we have collected about you.
- The categories of sources from which personal information is collected.
- Our business or commercial purpose is to collect personal information.
- The categories of third parties with whom we share personal information, if any.
- The specific pieces of personal information we have collected about you.
Your right to know is subject to exceptions provided in the law. For example, if the information about you is a client’s privileged information, you will not be able to exercise your right to know.
Right to obtain a copy of your personal information
If your data is available in a digital format, you have the right to obtain a copy of the personal information that you previously provided to us, in a portable and readable format (to the extent this is technically feasible).
Your right to obtain a copy of your information is subject to exceptions provided in the law. For example, if the information about you is a client’s privileged information, you will not be able to receive a copy.
Right to deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, and provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
- Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.
or
- Comply with an existing legal obligation.
We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception under the law applies. We will provide you with a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.
Right to correct inaccurate personal information
If we receive a verifiable request from you to correct your information and we determine the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you.
In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.
We also may require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.
We may deny your request to correct in the following cases:
- We have a good faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.
- We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
- Conflict with federal or state law.
- Another exception under the law.
- Inadequacy in the required documentation
- Compliance proves impossible or involves disproportionate effort.
We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information
Protection against discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under applicable laws. If you exercise your rights, we cannot:
- deny you services.
- charge different prices or fees for services, also through discounts, benefits, or fines.
- provide you with a different level or quality of service.
- propose that you receive different prices or tariffs for services.
Please note that we may charge a different fee or provide a different level or quality of services if the difference is reasonably related to the value we gain from your personal information.
Exercising your rights by yourself or through an authorized agent
If you would like to exercise any of your rights as described in this Policy, please contact us through one of the following channels:
- By sending us an e-mail at: [email protected]
- By contacting us by phone at our New York, Los Angeles, or Boston office. Our contact information is available here: https://www.pearlcohen.com/contact/
We will ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require and the nature of your request.
You may also designate an authorized agent to make a request on your behalf. To do so, you need to provide the authorized agent with written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.
Our response to your requests
We will respond to your requests within 45 days (or within 90 days, where the law permits, and we determine it necessary considering the complexity and number of the requests you have filed). If we take longer than 45 days, we will inform you of the extension within the initial forty-five-day response period, together with the reason for the extension.
We may deny your request in the following cases:
- If we believe in good faith, based on reasons which are documented in writing, that your request is fraudulent or is an abuse of your rights under applicable law.
- If we conclude that the request is irrelevant, based on all the circumstances at issue (e.g., if you requested to correct your personal information, and we find that it is likely to be accurate).
- If it is contrary to federal or state law.
- Due to a discrepancy in the required documentation.
- If the fulfillment of your request turns out to be impossible or involves disproportionate effort.
We will provide you with a detailed explanation including sufficient facts, to enable you to meaningfully understand why we cannot fulfil your request.
You may appeal our decision to deny your request by sending us an email at [email protected].