INTRODUCTION
- This Privacy Policy explains how we process, collect and use your personal data, and how, in doing so, we compl with our legal obligations. Your privacy is important to us, and we are committed to safeguarding and protecting your data privacy rights.
- We may amend this Privacy Policy from time to time. Please visit this page if you want to stay up to date.
GLOSSARY
- "Client" refers to individual and corporate purchasers of the firm's services, any ultimate beneficial owners or trust beneficiaries, any officers or representatives of any corporate entity or intermediaries, directors, members, shareholders and other beneficial owners of corporate entities.
- "Supplier" refers to partnerships, companies (including sole traders), third party service providers (including administrators and distributors), and atypical workers such as independent contractors and freelance workers, who provide services to the firm.
WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?
- The information described below is in addition to any personal data we are required by law to process in any given situation.
- CLIENT DATA: We may collect contact details or the details of individual contacts at your organisation (such as names, job title, telephone numbers, and postal or email addresses) in order to ensure our relationship runs efficiently, smoothly, and effectively. We may also collect date of birth, payment details, tax residence information, copies of photo identifications such as your driving licence and/or passport/identity card, information about nationality/citizenship/place of birth, your national identification number and identity verification documents in order to comply with our legal and regulatory obligations.Where relevant, we may also hold additional information that someone in your organisation has chosen to disclose to us. If we need any additional personal data for any reason, we will inform you.
- SUPPLIER DATA: We will collect your contact details or the details of individual contacts at your organisation (such as names, job title, telephone numbers, and postal or email addresses) in order to ensure our relationship runs smoothly. Depending on the circumstances, we may also collect bank details for pay purposes. We may also hold extra information that someone in your organisation has chosen to provide us.
- WEBSITE USERS: We collect a limited amount of data from website users, which we use to improve your experience when using our website and to help us manage the services we provide. This includes clicks and individual page visits, or any information tracked by third parties (such as Facebook, Google, Pinterest, etc.). We also collect aggregated, anonymized data. which is separate from any individual behavior tracked. If you contact us via the website, we will collect any information that you provide to us, for example your name and contact details.
HOW DO WE COLLECT YOUR PERSONAL DATA?
- CLIENT DATA: We collect Client personal data in three ways:
- Personal data that we receive directly from you; and
- Personal data that we receive from other sources.
Personal data that we receive directly from you
We will receive data directly from you in two ways:
- Where you contact us proactively; and/or
- Where we contact you.
Personal data we receive from other sources
Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
- From third party market research and by analysing online and offline media;
- From other limited sources and third parties.
- SUPPLIER DATA: We collect Supplier personal data in three ways:
- Personal data that we receive directly from you; and
- Personal data that we receive from other sources.
Personal data that we receive directly from you
We will receive data directly from you in two ways:
- Where you contact us proactively; and/or
- Where we contact you.
Personal data we receive from other sources
Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
- From third party market research and by analysing online and offline media;
- From other limited sources and third parties.
- WEBSITE USERS: When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes clicks and individual page visits, or any information tracked by third parties (such as Facebook, Google, Pinterest, etc.). We also collect aggregated, anonymized data. which is separate from any individual behavior tracked. We collect such data automatically via cookies, in line with cookie settings in your browser. We will also collect data from you when you contact us via our website, for example when you submit a query.
HOW DO WE USE YOUR PERSONAL DATA?
- Obtained data is utilized to enhance our connection with you.
- CLIENT DATA: We use such information for:
- Business Activities;
- Marketing; and
- To help us to establish, exercise or defend legal claims.
Here are some more details about each:
Business Activities
- Below are the various ways in which we use your data in order to ensure the smooth running of our agreements and dealings with you:
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to our relevant activities;
- To perform certain legal and regulatory obligations;
- Facilitating our invoicing processes; and
- Keeping records of our conversations and meetings, so that we can provide targeted services to you and in order to comply with our legal and regulatory obligations.
Marketing
- We may process your data for the purpose of targeting you with appropriate marketing campaigns, subject to any applicable local laws and requirements.
- If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by looking for the out-out disclaimer at the bottom of every such marketing material we issue.
To help us to establish, exercise or defend legal claims
- In rare circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
- SUPPLIER DATA: We use such information for:
- Business Activities;
- To help us to establish, exercise or defend legal claims.
Here are some more details about each:
Business Activities
- Below are the various ways in which we use your data in order to ensure the smooth running of our agreements and dealings with you:
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to our relevant activities;
- To perform certain legal and regulatory obligations;
- Facilitating our invoicing processes; and
To help us to establish, exercise or defend legal claims
- In rare circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
- WEBSITE USERS: We use your data to help us to improve your experience of using our website.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Where proper and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of entities:
- Any of our staff or agents;
- Audit, tax, regulatory bodies or other authorities, when we believe in good faith that the law or other regulation requires us to share this data;
- Third party outsourced IT and document storage providers;
- Third party service providers (including Suppliers) who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants);
- We do not sell any personally identifiable information provided to us to any unrelated third party, but, as set out above, we may share it with related entities or with unrelated third parties in connection with our own marketing activities or the maintenance and operation of our site, or as may be legally required. Please do not to send confidential or sensitive information to us through this website.
HOW DO WE SAFEGUARD YOUR PERSONAL DATA?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures.
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
- We will ordinarily process your data throughout the course of our interactions and will then generally retain it for an appropriate amount of time after we have parted ways, depending onour legitimate business and risk-management needs and local law requirements.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law provides you with certain rights. California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by us to third parties for those third parties' direct marketing purposes. To make such a request, please send a detailed description of the specific content or information to Robert.grijalba.esq@outlook.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even when requested.
Pursuant to California Civil Code Sections 1798.100 et seq., the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), California residents have the following, additional rights:
Your Right to Access to Specific Information and Data Portability. You may request that we disclose certain information to you about our collection and use of your personal information in the past 12 months. Once we receive and confirm your personal information request, you can request that we disclose some or all of:
- The categories of personal information we collected about you;
- Subject to certain limitations, the specific pieces of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we share that personal information; and
- If we sold or disclosed your personal information for a business purpose, two separate lists identifying: (a) the categories of your personal information collected and sold, and the categories of the third parties to whom the data was sold; and (b) the categories of your personal information that was disclosed for business purposes.
To make such a request, please use one of the methods identified in the Exercising Your CCPA Rights section of this policy. You may only submit two personal information requests of these kinds within a 12-month period.
Your Right to Request Correction. You may request that we correct non-accurate personal information that we maintain about you, subject to certain exceptions. Once we receive and confirm such a request, we will correct the personal information that is the subject of your request if we are able to do so, unless an exception applies. We may require documentation from you to verify that the personal information is inaccurate. We will only use such information for the purpose of processing your request and to comply with our record-keeping obligations. We may delete the personal information instead of correcting it if you consent to delete it or if the deletion would not negatively impact you.
Your Right to Request Deletion. You may request that we delete any or all of the personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your personal information request, we will delete from our records the personal information that is the subject of your request, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Comply with a legal obligation;
- Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our ongoing business relationship with you, provide a good or service that you requested, or otherwise perform our contract with you;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Comply with California Penal Code Section 1546 et seq. (the California Electronic Communications Privacy Act);
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another legal right; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Your Right to Opt-Out of Sale or Sharing. We do not sell personal information to third parties or share personal information for cross-context behavioral advertising. If that should change, we will make available to you a method to opt-out of such sale or sharing.
Exercising Your CCPA Rights. To exercise any of the CCPA rights described above, please tender a verifiable personal information request to us by:
Only you or a person that you have authorized in writing to act on your behalf may submit a personal information request. You may also make a personal information request on behalf of your minor child. The verifiable personal information request must:
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it; and
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or an authorized representative.
- For a request by the actual person, we will usually require a copy of a valid state-issued identification card, together with any email or physical address you have submitted to us and a valid phone number belonging to the individual making the request.
- For an authorized representative, we will usually require a copy of the signed authorization from the individual on whose behalf the agent is acting demonstrating the agent’s ability to act on that person’s behalf, a valid power of attorney, court appointment document or the agent’s registration with the California Secretary of State. Once we receive a personal information request from an authorized agent, unless that agent has a power of attorney issued pursuant to California Probate Code Sections 4121 to 4130, we may contact the person to whom the request relates in order to, among other things, verify their identity, confirm the agent’s capacity to act on that person’s behalf, and if applicable, respond to or deliver information requested pursuant to the personal information request.
- For a request related to a household, all members of the household must submit the request, and each must provide information sufficient for us to verify their identity. Usually, that will include, a copy of each household member’s valid state-issued identification card (or for minors under the age of 13, a signed consent of the minors’ guardian or parent), together with any email or physical address that may have been submitted to us and a valid phone number belonging to the individuals making the request. We may deny a request from a household if we cannot verify that the individual(s) making the request are part of the same household.