Privacy Policy

1. Introduction

Porter Hedges LLP (“we,” “our,” “us,” or the “Firm”) is a Houston, Texas-based law firm. This Privacy Policy describes the personal data or personally identifiable information subject to protection under applicable data protection laws that the Firm may collect, use, and/or disclose, as well as how the Firm collects, uses, discloses, and safeguards your personal information, when you visit our website, www.porterhedges.com (our “Website”), interact with our services, or otherwise communicate with us. This Privacy Policy applies to all personal information collected on or after the date it was last updated and replaces all prior versions. By accessing our Website or services, you acknowledge that you have read and understand this Privacy Policy.

Important: Browsing our Website or communicating with us does not create an attorney-client relationship. Such a relationship is formed only through a signed engagement letter or other formal written agreement with Porter Hedges LLP. Do not send confidential or sensitive information to the Firm through our Website unless such a relationship has been established.

2. Personal Information We May Collect

We may collect Personal Information when you provide it to us directly, automatically when you visit our Website, or from third parties, as explained in more detail in Section 3 (“How We May Collect Your Personal Information”).

In the last twelve (12) months, the categories of personal information that we have collected from individuals under this Privacy Notice include (hereafter, collectively referred to as “Personal Information”):

3. How We May Collect Your Personal Information

We may collect the categories of Personal Information listed in Section 2 (“Personal Information We May Collect”) in one or more of the following ways, depending on how you interact with us:

3.1 Information You Provide Directly

We may collect Personal Information from you when you directly interact with us. For example, we collect Personal Information from you when you submit information to us via forms on our Website, when you register for or attend our events, when you interact with our newsletters or other communications, when you apply for employment with us, when you make payments with us, or when you share information with us in connection with our legal services.

3.2 Information Collected Automatically

When you visit our Website, certain Personal Information is collected automatically through cookies, server logs, and similar technologies, including “internet or other electronic network activity information” and other, similar categories of Personal Information listed in Section 2 (“Personal Information We May Collect”).

3.3 Information from Third Parties

We may collect your Personal Information from various third parties. For example, we may collect your Personal Information from recruitment platforms when you apply for a position, from publicly-available sources (such as bar admissions, published articles, or other public professional information), or from data analytics providers.

4. How We Use Your Information

We use Personal Information for the following purposes, each supported by a legitimate business interest, contractual necessity, legal obligation, or your consent:

We limit our collection and use of personal information to what is reasonably necessary for these purposes and do not use it for materially different purposes. Furthermore, we do not use or disclose SPI for purposes other than the statutorily approved purposes specified in the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.121(a) (the “Permitted SPI Purposes”).

5. How We Share Your Information

We do not sell your Personal Information to third parties and have not sold any Personal Information in the preceding 12 months. We do not share your Personal Information with third parties for cross-context behavioral advertising purposes and have not done so in the preceding 12 months.

We may share/disclose your Personal Information with/to the following third parties:

5.1 Service Providers

We may share your Personal Information with service providers to perform certain services on our behalf, such as IT service providers, suppliers, mailing services, insurers, vendors or event organizers. This also includes our legal support vendors, such as e-discovery and deposition services, who perform services on our behalf in connection with your legal matter(s). We require these third-party service providers to use Personal Information only for the purposes for which it was disclosed and subject to appropriate confidentiality and security obligations.

5.2 Legal and Professional Obligations

We may disclose your Personal Information to third parties when we believe in good faith that disclosure is necessary to fulfill or comply with our legal and professional obligations, including without limitation:

5.3 With Your Consent

We may share your Personal Information when you expressly consent to share your Personal Information with third parties that you specify or for whom we have obtained your permission to disclose your Personal Information.

5.4 Business Purpose Disclosures

Over the last twelve (12) months, we have disclosed the categories of Personal Information discussed in Section 2 (“Personal Information We May Collect”) of this Privacy Notice with the third parties listed in Section 5 (“How We Share Your Information”) for the purposes listed in Section 4 (“How We Use Your Information”) of this Privacy Notice. If you are a California resident, please refer to the chart listed under Section 9.1 (“Business Purpose Disclosures Under the CCPA”). For any inquiries, please contact us using the details in Section 20 (“Contact Us”) of this Privacy Policy.

6. How We Protect Your Personal Information

We have implemented and maintain reasonable physical, electronic, and procedural safeguards designed to protect your Personal Information from unauthorized access or use consistent with applicable laws.

We use commercially reasonable administrative, physical, and technical measures designed to protect your Personal Information and other data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. These measures include, as appropriate, encryption, access controls, firewalls, secure server environments, and employee training.

However, no website, mobile application, system, electronic storage, or online service is completely secure, nor is any method of electronic storage or transmission over the internet completely secure, and we cannot guarantee its absolute security. Any transmission of personal data is at your own risk.

In the event of a security breach affecting your Personal Information, we will provide notification as required by applicable law, including the Texas Identity Theft Enforcement and Protection Act and/or any other applicable breach notification statutes.

7. Data Retention

We retain Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected. Specific retention criteria include:

The specific retention period depends on factors such as the nature of the Personal Information, the purposes for processing, applicable legal requirements, and our legitimate business needs. When Personal Information is no longer needed for any of these purposes, we will securely delete or de-identify it in accordance with our internal data-disposal procedures.

8. Your Privacy Rights Under State Data Privacy Laws

This Section describes additional rights provided to individuals in states with privacy laws that provide additional rights to their residents, including but not limited to, the Texas Data Privacy and Security Act (the “TDPSA”) and other applicable state data privacy laws (collectively, the “State Data Privacy Laws”).

For the purposes of this Section, “Personal Information” has the meaning given to “personal data,” “personal information,” or other similar terms in applicable State Data Privacy Laws, and it does not include information exempted from the scope of applicable State Data Privacy Laws.

8.1 State Data Privacy Rights

The State Data Privacy Laws may or may not provide certain rights to their residents related to their Personal Information. Therefore, we may decline your request in certain cases as permitted by applicable state law. Your rights under the State Data Privacy Laws may include:

8.2 Exercising Your State Data Privacy Rights

To exercise your rights or make a request under your applicable State Data Privacy Law, please contact us using one of the methods described in Section 20 (“Contact Us”).

To protect your privacy and security, we will verify your identity before fulfilling your request, which may require you to provide two or more pieces of information that match our records. For requests to access specific pieces of Personal Information or to delete Personal Information, we apply a higher standard of verification. We will not fulfill a request if we cannot reasonably verify that the person making the request is the person (or authorized representative of the person) about whom we collected Personal Information, and we will use Personal Information provided in a verification request solely for the purpose of verification.

Nothing in this Privacy Policy requires the disclosure of information protected by attorney-client privilege, the work-product doctrine, or any other applicable legal privilege or protection. We reserve the right to withhold information to the extent necessary to preserve these protections.

If you are a resident of a state that has a State Data Privacy Law that provides you with additional rights, you have the right to file a complaint with your state’s data privacy authority if you believe that we have not followed your applicable State Data Privacy Law. More information about your rights as a consumer may be found on the website for your state’s relevant regulatory agency.

9. Your Privacy Rights Under California Data Privacy Laws (California Residents)

This Section describes additional rights provided to California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the “CCPA”).

9.1 Business Purpose Disclosures Under the CCPA

The following chart identifies (1) the categories of Personal Information we may have disclosed to third parties over the preceding 12 months, which are defined/described in more detail in Section 2 (“Personal Information We May Collect”); (2) the categories of third parties to whom we may have disclosed Personal Information, which are defined/described in more detail in Section 5 (“How We Share Your Information”); and (3) the business purpose(s) for the disclosures, which are defined/described in more detail in Section 4 (“How We Use Your Information”):

Personal Information We May Collect

Third Parties to Whom We May Disclose Personal Information

Business Purpose(s) of Disclosure

Identifiers such as name, alias, address, unique personal identifier, online identifier, IP address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.

Service providers; professional advisors, clients, other parties, or the relevant authorities (if/as needed); and third parties that you specify.

Providing legal services; communications and marketing; recruitment; billing and payments; events; website improvement; security; and legal compliance.

Information falling within the personal information categories described in the California Customer Records statute, including education and employment history; professional organizations, licenses, and certifications; and bank account, credit card, or debit card numbers or any other financial or payment information.

Service providers; professional advisors, clients, other parties, or the relevant authorities (if/as needed); and third parties that you specify.

Providing legal services; recruitment; billing and payments; and legal compliance.

Protected classification characteristics under state or federal law.

Service providers; professional advisors, clients, other parties, or the relevant authorities (if/as needed); and third parties that you specify.

Providing legal services; recruitment; and legal compliance.

Internet or other electronic network activity information, including IP address, geolocation, and information collected through cookies, pixel tags, web beacons, and similar technologies.

Service providers; the relevant authorities (if/as needed); and third parties that you specify.

Providing legal services; communications and marketing; recruitment; billing and payments; events; website improvement; security; and legal compliance.

Non-public education information per the Family Educational Rights and Privacy Act, including grades, transcripts, and other education records directly related to a student.

Service providers; professional advisors, clients, other parties, or the relevant authorities (if/as needed); and third parties that you specify.

Providing legal services; recruitment; and legal compliance.

SPI, including government identifiers such as Social Security number, driver’s license, state identification card, or passport number; racial or ethnic origin; citizenship or immigration status; union membership; and health information.

Service providers; professional advisors, clients, other parties, or the relevant authorities (if/as needed); and third parties that you specify.

Providing legal services; recruitment; and legal compliance.


If you are a California resident, then you also have the following rights regarding your Personal Information:

9.2 Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information (the “right to know”), including the specific pieces of Personal Information we have collected about you (referred to as a “data portability request”). You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity, we will disclose to you:

When you submit a data portability request, you have the right to obtain a copy of your Personal Information in a portable, readily usable format that allows you to transmit it to another entity (where technically feasible). Thus, for data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

9.3 Right to Delete

You have the right to request that we delete the Personal Information we have collected from you. There are a number of exceptions, however, including but not limited to when the information is necessary for us or a third party to do any of the following:

9.4 Right to Correct

You have the right to request that we correct the Personal Information we have collected from you. There are a number of exceptions that may apply, which include:

9.5 Right to Limit SPI Use and Disclosure

You have a right to ask businesses that use or disclose your SPI to limit those actions to just the CCPA’s Permitted SPI Purposes. As we do not use or disclose SPI beyond the CCPA's Permitted SPI Purposes, we do not currently provide this consumer right.

9.6 Right to Opt-Out of and/or Opt-In to Personal Information Sales or Sharing

You have the right to request that businesses stop selling or sharing your Personal Information at any time. Similarly, the CCPA prohibits businesses from selling or sharing the Personal Information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13. Because we do not sell or share consumers’ personal data other than as provided in Section 5 (“How We Share Your Information”), we do not currently provide these consumer rights.

9.7 Right to Non-Discrimination/Retaliation

You have the right to be free from discrimination by us as a result of exercising your privacy rights under the CCPA, including by denying service or suggesting that you will receive different rates for services or a different level or quality of service. This also includes the right of an employee, job applicant, or independent contractor to not face retaliation for exercising their CCPA rights.

9.8 Exercising Your California Data Privacy Rights

To exercise your rights as a California resident, please contact us using one of the methods described in Section 20 (“Contact Us”). You can also find more information about your rights as a California resident on the California Privacy Protection Agency’s website.

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your Personal Information. To designate an authorized agent, please follow the instructions set forth in Section 20 (“Contact Us”). We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your Personal Information.

We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the Personal Information relating to you. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make the request. For requests to limit or opt-out (if and where permitted), we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing it.

10. We Do Not Sell Your Personal Information

We do not sell Personal Information to third parties for monetary or other valuable consideration as defined under applicable State Data Privacy Laws, including the TDPSA and the CCPA.

We also do not “share” Personal Information for cross-context behavioral advertising as that term is defined under the CCPA. While our Website may use limited third-party analytics tools (such as Google Analytics), we have configured these tools to function as service providers processing data on our behalf, rather than as recipients of “shared” data for their own advertising purposes. We do not deploy advertising pixels or retargeting technologies that would constitute a “sale” or “sharing” of Personal Information under applicable law.

Because we do not sell or share Personal Information, we are not required to provide a “Do Not Sell or Share My Personal Information” link. However, we honor opt-out preference signals as described in Section 14 (“Do Not Track and Global Privacy Control Signals).

We do not sell or otherwise disclose SPI or biometric data.

11. Your Privacy Rights in the European Economic Area or the United Kingdom

Except as otherwise specified herein, the information provided in this Section applies only to individuals in European Economic Area (the “EEA”) and the United Kingdom (the “UK”). References to “Personal Information” in this Privacy Notice are equivalent to “personal data” as governed by European data legislation, such as the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the UK Data Protection Act of 2018 and the Data (Use and Access) Act of 2025 (collectively, the “European Data Legislation”). For purposes of the European Data Legislation, your Personal Information will be controlled by the Firm.

We only process your Personal Information as described in this Privacy Policy based on contractual necessity, legitimate interests (including operating our Website, marketing our services, managing client relationships, and providing our services), compliance with legal obligations, and/or with your consent.

11.1 EEA and UK Data Privacy Rights

If you are a resident of the EEA or the UK, you have the following rights regarding your Personal Information:

We may collect special categories of Personal Information about you when we act as a data controller. Special categories of Personal Information include specific demographic details such as race, ethnicity, and sexual orientation. If you choose to disclose this information in connection with our services or for potential employment, we may collect details about your race, ethnicity, and sexual orientation. Additionally, as part of background checks conducted on job applicants and/or clients and in providing services on behalf of our clients, we may also collect information about prior criminal convictions and offenses, along with other special categories of Personal Information. If we collect special categories of Personal Information, we will process such information only where we have a valid legal basis to do so, including where processing is necessary for compliance with legal obligations, the establishment, exercise, or defense of legal claims, or where you have provided explicit consent.

To exercise your rights under the European Data Legislation by contacting us directly, please see Section 20 (“Contact Us”).

If you are in the EEA, you have the right to file a complaint with your local data protection authority if you believe we have not followed applicable data protection laws. You can find a list of local data protection authorities in EEA countries at the following link: https://www.edpb.europa.eu/about-edpb/our-members_en.

If you are in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), as explained in more detail on their website: https://ico.org.uk/make-a-complaint/.

11.2 Data Protection Complaint

If you are in the UK, you have the right to submit a data protection complaint to us about any aspect of how the Firm processes personal data, including with respect to:

If you are unhappy and wish to discuss your concerns around your personal data and/or how it is handled, please contact info@porterhedges.com with the subject line “Data Protection Complaint.” Your complaint will be acknowledged within 30 days and resolved as soon as reasonably practical.

If you are dissatisfied with our response to your data protection complaint, you have the right to lodge a complaint with the ICO, which can be contacted via its website: www.ico.org.uk or Telephone: 0303 123 1113. Raising a complaint with the ICO does not affect any other legal rights or remedies you may have.

12. International Data Transfers

Porter Hedges LLP is based in the United States, and our Website servers are located in the United States. If you are accessing our Website from outside the United States, please be aware that your Personal Information will be transferred to, stored in, and processed in the United States, where data-protection laws may differ from those in your country of residence.

By using our Website or providing us with your Personal Information, you acknowledge and consent to this transfer. Where required by applicable law, we will implement appropriate safeguards for cross-border transfers of Personal Information, which may include Standard Contractual Clauses approved by the European Commission, the UK International Data Transfer Addendum, or reliance on the EU-U.S. Data Privacy Framework (or its successor), as applicable.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may have additional rights under the GDPR or equivalent local law, including the right to lodge a complaint with your local supervisory authority.

13. Cookies and Tracking Technologies

Our Website uses cookies and similar technologies to support core website functionality, analyze website traffic, and understand how visitors interact with our site. A “cookie” is a small data file placed on your device when you visit a website.

13.1 Our Hosting Platform’s Cookie Practices

Our Website is hosted on the Firmseek platform. Firmseek’s servers do not use cookies or tracking technologies beyond a single browsing session, except as described below. Temporary session cookies support forms and multi-step processes and are discarded when you close your browser. Because these cookies are strictly functional, they do not require consent under the General Data Protection Regulation (GDPR) or similar laws.

Google Fonts used on our Website are downloaded and served locally from our servers; no data is shared with Google through font delivery. Adobe Fonts and Monotype fonts used on our site do not use cookies or collect Personal Information.

13.2 Specific Cookies Used on Our Website

The following cookies may be placed on your device when you visit our Website:

Cookie Name

Duration

Purpose

cookies_opted_in

10 years

Stores your response to the cookie consent banner

PHPSESSID

Session

Stores user session identifier for forms and login functionality

firmseek_packet

Session

Stores items selected for the PrintPilot document packet feature

newsletter-origin

Session

Stores newsletter click-tracking source data to attribute website visits to newsletter links

13.3 Third-Party Analytics and Tracking

We use Google Analytics to collect aggregated information about how visitors use our Website. Google Analytics uses its own cookies to collect this data. Information collected by Google Analytics is transmitted to and stored by Google. You can learn about Google’s practices at https://policies.google.com/privacy.

Our Website may also integrate Google reCAPTCHA on certain forms to prevent automated abuse. When present, Google reCAPTCHA is identified by a badge in the bottom-right corner of the page and is subject to Google’s Privacy Policy and Terms of Service.

Third-party tracking scripts (such as analytics or social media tools) collect data directly from your browser; this data is not transmitted by our servers to those third parties. Our hosting platform does not share your Personal Information with third-party software providers.

13.4 Pixel Tags and Web Beacons

We may use pixel tags (also known as web beacons or clear GIFs) in our email communications to determine whether messages have been opened and links clicked. This helps us measure the effectiveness of our communications and improve future content.

13.5 Managing Your Cookie Preferences

You can manage or disable cookies through several methods:

14. Do Not Track and Global Privacy Control Signals

We recognize and honor Global Privacy Control (“GPC”) signals. When we detect a GPC signal from your browser, we will treat it as a valid opt-out request for the sale or sharing of Personal Information and targeted advertising, as required by the Texas Data Privacy and Security Act and the California Consumer Privacy Act.

Some browsers offer a “Do Not Track” (“DNT”) setting. While there is no uniform industry standard for responding to DNT signals, we treat DNT signals in the same manner as GPC signals and will strive to honor them as opt-out requests. For more information, visit https://globalprivacycontrol.org.

15. Third-Party Websites and Links

Our Website may contain links to third-party websites, services, or resources that are not owned or controlled by the Firm, including embedded content from Google Maps, YouTube, and Vimeo. This Privacy Policy does not apply to those third-party sites or services and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party websites you visit.

16. Social Networking Plugins

Our Website may include plugins or features from third-party social networking services, including X and LinkedIn. These plugins may allow the social networking service to collect information about your visit to our Website, such as the pages you viewed, even if you do not click on the plugin or have an account with that service.

Information collected by social media plugins is subject to the privacy policies of the respective social networking services. We encourage you to review their privacy policies:

We do not control and are not responsible for the data practices of these third-party services.

17. Artificial Intelligence

We may use artificial intelligence (“AI”) tools in connection with certain internal operations, research, or administrative functions. Any use of AI tools is subject to human oversight and review and is governed by the Firm’s confidentiality obligations and professional responsibilities. We do not use AI tools to make automated decisions that produce legal or similarly significant effects on individuals without human involvement.

18. Children’s Privacy

Our Website and services are directed to adults and are not intended for use by children. We do not knowingly collect Personal Information directly from individuals under the age of majority in their jurisdiction. If we learn that a child, as defined by the laws of their applicable jurisdiction, has provided us with Personal Information, we will delete that information from our records unless we are legally required to retain it.

We do not knowingly sell or share Personal Information, or process Personal Information for targeted advertising, with respect to individuals under sixteen (16) years of age. If you are under age 16, please do not submit Personal Information to us without the involvement of a parent or guardian.

We do not sell your Personal Information, nor knowingly sell or share the Personal Information of individuals under the age of 16 (and have not done so during the prior 12 months).

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational or legal reasons. When we make material changes, we will update the “Last Updated” date at the top of this policy and post the revised version on our Website. We encourage you to review this Privacy Policy periodically.

Your continued use of our Website or services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

20. Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or our privacy practices, including requests to exercise any of your data privacy rights, please contact us directly by mail, email, or phone:

Porter Hedges LLP
1000 Main Street, 36th Floor
Houston, Texas 77002
Email: info@porterhedges.com
Phone: (713) 226-6000
Toll-free: (888) 226-2777

You may also designate an authorized agent to submit a request on your behalf. If you use an authorized agent, we may require: (a) proof of your signed, written authorization; (b) verification of your identity directly; or (c) evidence that the agent holds a valid power of attorney under applicable law.

Though we never sell data, we may use third-party marketing tools on our Website for targeted or cross-contextual advertising or profiling, and we may use performance analytics tools such as Google Analytics to measure and improve our Website. You can opt-out of our use of these tools by visiting the opt-out link provided in Section 13 (“Cookies and Tracking Technologies”) below. You may also manage your cookie preferences at any time through the consent management tool accessible via the link located in the footer of our Website.

We will contact you to confirm receipt of your request under the European Data Legislation, the State Data Privacy Laws, the CCPA, or other data protection laws and request any additional information necessary to verify your request. We verify requests by matching the information provided in connection with your request to the information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request that you verify your identity. You may also designate an authorized agent to make a request under certain privacy laws on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

The verifiable consumer request must:

We will not be able to respond to your request or provide you with specific pieces of Personal Information if we cannot verify your identity and authority to make the request.

We will respond to verifiable privacy requests within the timeline required by applicable law, including the CCPA and/or the applicable State Data Privacy Laws. If we cannot meet that timeline, we will inform you in writing. Please contact us at info@porterhedges.com with any questions about this Privacy Notice.

21. Additional Disclosures and Disclaimers

21.1 Limitation of Liability

To the fullest extent permitted by applicable law, the Firm disclaims all liability for the unauthorized access to, alteration, theft, or destruction of Personal Information through accident, fraud, or any force or cause beyond our reasonable control, including the failure of electronic or mechanical equipment, telephone or other communication problems, and unauthorized access to our systems.

21.2 Consent by Use

By using our Website or providing Personal Information to us, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. Where required by applicable law, we will obtain your explicit consent before collecting or processing SPI.

21.3 Governing Law

This Privacy Policy is governed by the laws of the State of Texas, without regard to conflict-of-law principles. However, federal law will apply where it preempts state law; the privacy laws of other states (including the CCPA/CPRA for California residents) will apply to individual rights as described in Section 8 (“Your Privacy Rights Under State Data Privacy Laws”) and Section 9 (“Your Privacy Rights Under California Data Privacy Laws”); and the privacy laws of the EEA or the UK will apply to individual rights as described in Section 11 (“Your Privacy Rights in the European Economic Area or the United Kingdom”).

21.4 Sole Discretion

Porter Hedges LLP reserves the right, in its sole discretion, to modify, suspend, or discontinue any aspect of its Website or services at any time without notice or liability.

Last Updated: October 20, 2026

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