Privacy Policy

This Policy applies when you:

visit a website or webpage operated by Athena that links to this Policy;

submit an inquiry or request through the website;

ask to receive Athena updates or event information;

communicate with Athena about a possible engagement, business relationship, event, publication, or employment opportunity; or

otherwise interact with Athena in circumstances where this Policy is provided.

This Policy does not govern information Athena receives or maintains in the course of representing a client. Client and matter information is governed by the applicable engagement agreement, Athena's professional obligations, and any matter-specific notice. Nothing in this Policy reduces any protection arising from an attorney-client relationship, attorney-client privilege, work-product protection, a lawyer's duty of confidentiality, or other applicable law.

This Policy also does not govern a third-party website, platform, or service that Athena does not control, even if the website links to it. A supplemental notice may apply to a particular service, event, recruiting process, or other interaction. If a supplemental notice conflicts with this Policy for that interaction, the supplemental notice controls.

Athena may collect the categories of personal information described below. We use this information to operate and secure the website, respond to you, evaluate potential engagements and conflicts, provide requested communications, understand and improve the website, comply with law and professional obligations, and protect Athena and others.

Athena may disclose these categories to service providers, professional advisers and insurers, authorities or other recipients required by law, transaction participants, and recipients you direct. Athena does not sell personal information for money and does not use website information for targeted or cross-context behavioral advertising.

We retain each category only for as long as reasonably necessary for the purpose for which it was collected, taking account of legal and professional requirements, security, disputes, and recordkeeping needs. Sections 3 through 10 provide the detailed collection, use, disclosure, technology, and retention information required to understand this notice.

Website inquiry-form notice at collection. At or before submission, the inquiry form should state: “Privacy notice: We collect the email address, inquiry type, message, and related technical information you submit or generate to respond, route the inquiry, evaluate potential engagements and conflicts, secure the Website, and maintain appropriate records. Athena does not sell this information or share it for cross-context behavioral advertising. See this Privacy Policy for categories, recipients, retention, and applicable rights. Do not include confidential or time-sensitive information. Submitting this form does not create an attorney-client relationship.”

The information Athena collects depends on how you interact with us. You are not required to provide personal information merely to read public website content, although the website automatically generates limited technical and usage information.

Contact and identity information

This category may include your name, email address, telephone number, mailing address, online identifier, and similar contact details. The website's current public inquiry form requires an email address and an inquiry type. We receive this information directly from you, from a person who introduces or refers you, or from a business or professional source.

Athena uses contact and identity information to respond to you, route a request, perform intake and conflicts procedures, maintain business records, send requested communications, authenticate a privacy request, protect the website, and comply with legal or professional requirements.

Communications and inquiry information

This category includes the contents of a website message, email, request, feedback, or other communication; the subject and timing of communications; and information necessary to evaluate a potential engagement or business relationship.

Do not submit confidential, privileged, time-sensitive, or detailed matter information through the public website. Submitting information through a public form or sending an unsolicited email does not by itself create an attorney-client relationship. Section 4 explains how Athena uses inquiry information, and Athena's Website Terms of Use and Legal Notices provide additional professional-responsibility disclosures.

Professional and business information

This category may include your employer or organization, title, professional role, industry, business contact information, professional interests, and information associated with a referral, event, publication request, or possible engagement. Athena may receive this information from you, a colleague or referral source, professional networks, public professional sources, or a service provider supporting Athena's business operations.

Marketing and preference information

This category may include whether you asked to receive Athena updates, the subjects that interest you, your communication preferences, campaign attribution information, and your interaction with Athena communications. Athena uses this information to provide requested updates, administer preferences, measure communications, and avoid sending communications after you opt out.

Device, network, and usage information

When you use the website, Athena and its service providers may automatically collect:

your internet protocol address and approximate location derived from it;

browser type and version, device type, operating system, language, and similar technical information;

pages viewed, links selected, referring page, date and time of access, navigation path, session duration, and website errors;

campaign parameters, including UTM source, medium, campaign, term, and content; and

identifiers used to operate, secure, and analyze the website, including an analytics identifier.

Athena uses this information to deliver website content, maintain availability, detect abuse, understand aggregate website use, measure communication effectiveness, diagnose errors, and improve the website.

Approximate location information

Athena may infer a general city, region, or country from an internet protocol address. Athena does not use the public website to collect precise geolocation from your device.

Information about another person

If you provide information about another person, you should have authority or permission to do so. Do not refer a person to Athena or share that person's contact information unless doing so is lawful and appropriate.

Sensitive personal information

Athena does not ask you to provide sensitive personal information through the public website. A free-text message could nevertheless reveal information such as government identifiers, account credentials, financial information, health information, precise location, racial or ethnic origin, religious beliefs, sexual orientation, immigration status, or the contents of private communications.

Do not include this information in a public website submission. If Athena receives sensitive personal information, Athena will use it only as reasonably necessary to respond, evaluate an inquiry, protect security, comply with law or professional obligations, or for another purpose permitted by law. Athena does not use sensitive personal information collected through the website to infer characteristics about you.

Athena may collect personal information from:

you, including through forms, email, event interactions, or other communications;

your device and browser when you use the website;

a person or organization that introduces, refers, or communicates about you;

public sources, including professional websites, public records, and information you make publicly available;

professional networks, event organizers, or organizations with which Athena has a business relationship; and

vendors that provide hosting, analytics, security, communications, or other operational support.

Athena may combine information from these sources when reasonably necessary for the purposes described in this Policy.

Athena may use personal information for the following purposes.

Website delivery and operations

We use information to provide website functions, display content, remember functional choices, maintain performance, diagnose errors, and administer our systems.

Inquiries, intake, and potential engagements

We use information to respond to a request, understand the nature of an inquiry, route it to the appropriate person, conduct intake and conflicts procedures, determine whether Athena can accept an engagement, and communicate about next steps. Processing an inquiry does not mean that Athena has accepted an engagement.

Communications and marketing

We use contact, professional, preference, and campaign information to provide publications or updates you request; invite you to relevant events if offered; communicate about Athena's services; administer subscriptions; and measure the effectiveness of communications. Where applicable law requires consent, Athena relies on consent. You may opt out of marketing at any time.

Analytics and improvement

We use device, network, usage, and campaign information to understand how the website is found and used, identify useful or underperforming content, improve navigation and performance, and develop aggregate statistics.

Security, fraud prevention, and protection

We use information to authenticate requests, detect and investigate suspicious activity, prevent spam and abuse, protect Athena's systems and information, and protect the rights, safety, privacy, and property of Athena, our clients, visitors, and others.

Compliance and professional obligations

We use information to comply with law, court orders, regulatory requests, recordkeeping requirements, sanctions and conflicts obligations, and rules of professional conduct. We may also use information to establish, exercise, or defend legal claims; enforce website terms; respond to complaints; and cooperate with lawful investigations.

Deidentified and aggregate information

Athena may create aggregate or deidentified information that does not reasonably identify you. We may use that information to analyze website performance, improve operations, and produce internal statistics. Where law requires, Athena will maintain deidentified information in deidentified form and will not attempt to reidentify it except to test whether deidentification measures work.

Compatible or consented uses

Athena may use information for another purpose that is compatible with the purpose disclosed when the information was collected, as permitted by law. If consent is required for a materially different purpose, Athena will request it.

If and to the extent Regulation (EU) 2016/679 (the “GDPR”) or the United Kingdom General Data Protection Regulation (the “UK GDPR”) applies, Athena relies on one or more of the following legal bases:

steps requested before entering a contract or performance of a contract, such as responding to an inquiry you ask us to evaluate;

Athena's legitimate interests in operating and securing the website, communicating with professional audiences, developing the firm, improving services, preventing misuse, and protecting legal rights, provided those interests are not overridden by your rights and interests;

your consent, including for marketing or nonessential technologies where consent is required;

compliance with legal and professional obligations; and

establishment, exercise, or defense of legal claims.

The legal basis depends on the information, purpose, and context. You may contact Athena for information about the basis applicable to a particular processing activity.

Athena generally applies these bases as follows: responding to an inquiry and taking requested steps before a potential engagement may rely on pre-contractual steps and Athena’s legitimate interests; operating, securing, troubleshooting, and improving the Website may rely on Athena’s legitimate interests, with consent used for nonessential analytics or storage where required; requested updates and marketing may rely on consent or legitimate interests, subject to applicable opt-out and objection rights; and compliance, conflicts, recordkeeping, and claims-related processing may rely on legal obligations, professional obligations, legitimate interests, or the establishment, exercise, or defense of legal claims, depending on the circumstances.

Athena may disclose personal information to the following categories of recipients.

Service providers

We may disclose information to providers of website hosting, cloud infrastructure, information security, analytics, communications, document and data management, professional services, and related operational support. They process information to provide services to Athena.

Professional advisers and insurers

We may disclose information to Athena's lawyers, accountants, auditors, consultants, banks, and insurers when reasonably necessary for their services, risk management, or legal claims.

Clients, prospective clients, and engagement participants

If you ask Athena to consider or perform an engagement, information may be disclosed as reasonably necessary for conflicts analysis, intake, or the engagement, subject to applicable professional obligations. Once Athena accepts an engagement, the handling of client and matter information is governed by the engagement agreement and professional duties rather than this website Policy.

Authorities and other legally required recipients

We may disclose information to courts, regulators, law-enforcement agencies, professional authorities, or other parties when Athena believes disclosure is required or permitted by law or professional obligations, or is reasonably necessary to protect rights, safety, privacy, or property.

Business transaction participants

We may disclose information in connection with a proposed or completed financing, reorganization, combination, transfer, or other transaction involving all or part of Athena's operations. Athena will use appropriate confidentiality and use restrictions where reasonably available.

Recipients you direct

We may disclose information to a person or organization at your direction, with your consent, or when necessary to provide a service you request.

Athena and its service providers may use cookies, local storage, session storage, pixels, tags, logs, and similar technologies. The technologies currently relevant to the public website fall into two categories.

Necessary and functional technologies

These technologies operate the website, maintain security, remember a functional choice, or provide a feature you request. The website currently uses local storage to remember whether a visitor has recently seen the introductory animation.

Analytics technologies

Athena currently uses PostHog to understand website use and performance. PostHog may process a website identifier, device and browser information, pages and events, referral information, and related usage data. The website also stores UTM campaign parameters in session storage during a browsing session.

Where applicable law requires consent before Athena activates nonessential analytics, Athena will request consent. If the website displays privacy or cookie controls, you may use them to change your choices. You may also configure your browser to block or delete storage technologies, although some website functions may not work as intended.

Athena does not currently use the public website to serve third-party advertising or to track visitors across unrelated websites for targeted advertising.

Do Not Track and Global Privacy Control

Some browsers transmit a "Do Not Track" signal. Because there is no uniform industry standard for interpreting that signal, the website does not currently respond to it.

Athena treats a legally recognized opt-out preference signal, such as Global Privacy Control, as a request to opt out of sale, sharing, or targeted advertising where applicable law requires. Because Athena does not currently sell website information or use it for targeted or cross-context behavioral advertising, such a signal may not change the website's current behavior.

Athena does not sell personal information for money. Athena does not share personal information for cross-context behavioral advertising and does not process website information for targeted advertising as those terms are defined by applicable U.S. state privacy laws.

Athena does not knowingly sell or share personal information of anyone under 16. Athena does not offer a financial incentive or price or service difference in exchange for personal information collected through the website.

If Athena's practices change, Athena will update this Policy and provide any notice, consent, or opt-out method required before applying the change to personal information.

Athena retains personal information only for as long as reasonably necessary for the purpose for which it was collected and for compatible legal, professional, security, and recordkeeping purposes.

In determining a retention period, Athena considers:

the nature and sensitivity of the information;

the purpose of collection and whether that purpose can be achieved another way;

the duration of an inquiry, subscription, business relationship, or dispute;

risks associated with unauthorized use or disclosure;

legal, regulatory, insurance, accounting, conflicts, and professional-responsibility requirements; and

the need to establish, exercise, or defend legal claims.

Website logs and analytics information are generally retained for a shorter period than business correspondence or records needed for conflicts, compliance, or legal claims. When personal information is no longer required, Athena may delete it, securely dispose of it, or deidentify it. Backup copies may remain for a limited period until overwritten or deleted through ordinary system processes.

Marketing communications

You may opt out of marketing email by using the unsubscribe link in the message or contacting Athena. Athena may continue to send non-marketing communications, including responses to your requests and communications concerning an existing relationship.

Technology controls

You may use any privacy controls displayed on the website and the controls available in your browser or device. Blocking storage technologies may affect website functions. A browser opt-out is generally specific to that browser and device and may be lost if you clear browser data.

Declining information

You may decline to provide optional information. Athena may be unable to respond to an inquiry, evaluate a potential engagement, or provide a requested communication if required information is not supplied.

Correcting information

You may ask Athena to correct or update contact information or communication preferences. Athena may retain prior information where required for conflicts, compliance, security, professional obligations, or legal claims.

Depending on where you live and the law that applies, you may have a right to:

confirm whether Athena processes your personal information;

request access to or specific information about personal information Athena holds;

request correction of inaccurate information;

request deletion of personal information;

receive a portable copy of information you provided;

object to or restrict certain processing;

withdraw consent for future processing;

opt out of sale, sharing, targeted advertising, or certain profiling;

appeal Athena's decision on a request; and

receive equal service and not be discriminated against for exercising a privacy right.

These rights are not absolute. Athena may decline or limit a request where the law permits or where information is protected by privilege, professional duties, another person's rights, security requirements, or an applicable exemption.

To submit a request, email contact@athena.lawyer or use the website contact form and identify the message as a privacy request. Describe the right you want to exercise and the information involved.

Athena may request information reasonably necessary to verify your identity and authority. Athena will use verification information only to process the request. Where law permits an authorized agent to act for you, Athena may request evidence of the agent's authority and may also verify your identity directly. If applicable law provides an appeal right, you may appeal by replying to Athena's decision and explaining why you believe it should be reconsidered.

This section applies only if and to the extent Athena and the relevant personal information are subject to a U.S. state privacy law, including the California Consumer Privacy Act as amended ("CCPA"). Nothing in this section is an admission that Athena meets a law's coverage threshold or that a particular right applies to information that is exempt from the law.

This Policy is also intended to provide the disclosures required by the California Online Privacy Protection Act (CalOPPA), where applicable, including categories collected, third-party disclosure categories, choices, effective-date and change information, and online-tracking disclosures.

Categories collected and disclosed

During the 12 months preceding the effective date, and depending on the interaction, Athena collected the following statutory categories and may have disclosed them for the business purposes described below, to the extent the CCPA applies:

Identifiers. Examples include name, email address, telephone number, mailing address, internet protocol address, and website or analytics identifiers. Sources include you, your device, referral sources, public professional sources, and service providers. Recipients may include service providers, professional advisers and insurers, authorities, and recipients you direct.

California customer-record information. Examples include contact information and other information described in California Civil Code section 1798.80(e) that you choose to provide. Sources and recipients are the same categories described for identifiers.

Professional or employment-related information. Examples include employer, organization, title, role, professional interests, and business contact details. Sources include you, referral sources, professional networks, public sources, and service providers. Recipients may include service providers, professional advisers, engagement participants where appropriate, and recipients you direct.

Internet or other electronic-network activity. Examples include browser and device information, pages viewed, links selected, referral information, UTM parameters, interaction events, timestamps, and session information. Sources include your browser, device, and analytics or hosting providers. Recipients may include hosting, security, and analytics providers and professional advisers.

Geolocation data. Athena may infer an approximate city, region, or country from an internet protocol address. Athena does not collect precise geolocation through the public website. Recipients may include hosting, security, and analytics providers.

Communications and other information you submit. A free-text inquiry may contain information that falls within another statutory category. Athena does not require sensitive personal information through the public website and does not use it to infer characteristics.

Athena uses these categories for the business and commercial purposes described in Section 5. Athena retains them according to the criteria in Section 10. Athena does not sell or share these categories for cross-context behavioral advertising and has not done so during the period covered by this Policy.

California rights and disclosures

Subject to the CCPA's scope, exemptions, and verification requirements, a California resident may request to know, access, correct, or delete personal information and may request information about categories, sources, purposes, and recipients. Because Athena does not sell or share personal information for cross-context behavioral advertising, Athena does not currently provide a "Do Not Sell or Share My Personal Information" link.

Athena does not use or disclose sensitive personal information for purposes that would require a right to limit under the CCPA. Athena does not provide a financial incentive for personal information collected through the website. Athena will not discriminate against a person for exercising an applicable CCPA right.

Certain information may be outside the CCPA or exempt, including information protected by privilege or professional duties and information processed in some business-to-business or employment contexts where an exemption applies.

This section applies only if and to the extent processing of your personal information is governed by the GDPR or UK GDPR. Athena is established in California, does not have an office or establishment in the EEA or United Kingdom, and does not intentionally direct the public Website to or monitor individuals there.

Controller

Athena Circle, a Professional Law Corporation is the controller for personal information covered by this Policy. Athena's contact information appears in Section 20.

Legal bases

The legal bases Athena generally relies on are described in Section 6. If Athena relies on legitimate interests, you may request additional information about the relevant interest and balancing considerations.

GDPR and UK GDPR rights

Subject to applicable conditions and exemptions, you may have rights of access, rectification, erasure, restriction, objection, and data portability, and the right to withdraw consent at any time. Withdrawal does not affect processing that was lawful before withdrawal.

You may object at any time to direct marketing. You may also object to processing based on legitimate interests, in which case Athena will stop unless Athena demonstrates compelling legitimate grounds or the processing is needed for legal claims.

Athena does not use personal information covered by this Policy to make a solely automated decision that produces legal or similarly significant effects concerning you.

Complaints

You may lodge a complaint with the data-protection authority in the country where you live, work, or believe an infringement occurred. Athena asks that you contact us first so that we have an opportunity to address the concern, but you are not required to do so.

Transfers from the EEA or United Kingdom to the United States

Athena is based in the United States, and personal information may be processed in the United States or another country where Athena's service providers operate. Those countries may not provide the same level of protection as your home jurisdiction. If applicable law restricts a transfer, Athena will use a lawful transfer mechanism, which may include an adequacy decision, approved standard contractual clauses, or another mechanism recognized by law.

You may contact Athena for information about safeguards applicable to a transfer of your personal information.

Athena uses administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, loss, or disclosure. Safeguards are selected in light of the nature of the information and the risks presented by processing.

No internet transmission or storage system is completely secure. Athena cannot guarantee absolute security, and email and public website forms may be insecure. Do not use a public form or unsolicited email to send client documents, confidential deal information, account credentials, government identifiers, or other sensitive information. Existing clients should use the communication and file-transfer methods specified for their engagement.

If you believe information submitted to Athena has been compromised, contact Athena promptly.

The website may link to or integrate content or services operated by another organization. Athena does not control and is not responsible for the third party's content, security, availability, or privacy practices. A link or integration does not by itself imply endorsement or affiliation. Review the third party's privacy notice before providing information to it.

The website is intended for business and professional audiences and is not directed to anyone under 18. Athena does not knowingly collect personal information from children through the website. If you believe a child provided personal information in a manner prohibited by law, contact Athena. Athena will review the report and delete the information when required.

Athena may update this Policy to reflect changes in law, technology, services, or information practices. Athena will post the revised Policy and update the effective date. If a change is material, Athena will provide additional notice through the website or another appropriate method when required by law. Unless otherwise stated, a revised Policy applies when it becomes effective.

If you need this Policy in an alternative format or have difficulty accessing it, contact Athena using the information below. Athena will work with you to provide reasonable access to the information.

Questions, concerns, and privacy requests may be directed to:

Athena Circle, a Professional Law Corporation

345 California Street, Suite 600

San Francisco, California 94101

contact@athena.lawyer