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Hogan complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from the European Union and the United Kingdom. Hogan has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit


Notice: When Hogan collects your personal information, we’ll give you timely and appropriate notice describing what personal information we’re collecting, how we’ll use it, and the types of third parties with whom we may share it.

Choice: Hogan gives you choices about the ways we will use and share your personal information, and we’ll respect the choices you make. If Hogan were to ever engage in any onward transfers of your data with third parties other than our agents, we would provide you with an opt-out choice to limit the use and disclosure of your personal data.

Onward Transfer: Hogan will not disclose your information to unaffiliated third parties without first obtaining your permission, unless of course it’s to meet national security or law enforcement requirements. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, we are liable for appropriate onward transfers of personal data to third parties.

Security: Hogan takes appropriate physical, technical, and organizational measures around security, availability, processing integrity, and confidentiality to protect personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction.

Data Integrity: Hogan takes appropriate steps to make sure the personal information in our records is accurate.

Relevance: Hogan collects only as much personal information as we need for specific, identified purposes, and we won’t use it for other purposes without obtaining your consent.

Retention: Hogan keeps your personal information for as long as required to fulfill the purposes for which it was collected, or as permitted by law.

Access: Hogan acknowledges that EU individuals have the right to access the personal information that we maintain about them. Hogan provides ways for you to access your personal information, as required by law, so you can correct inaccuracies (see Access to Information above).

Enforcement: Hogan regularly reviews how we’re meeting these privacy promises, and we provide an independent way to resolve complaints about our privacy practices. Hogan is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Independent Recourse: In compliance with the Privacy Shield Principles, Hogan commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact Hogan (see Contact Us above).

Binding Arbitration: Residents of the European Union, under certain conditions, may elect to invoke binding arbitration for unresolved complaints.

Hogan commits to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. This service is provided free of charge to you.