(A) This Policy
This Policy is issued by Privatus Counsel, a professional limited liability company registered in the District of Columbia in the United States of America.
This Policy is addressed to individuals outside our organisation with whom we interact, including individual clients, representatives of client organisations, visitors to our Sites, users of our Apps, and other users of our services (together, “you”).
(B) Collection of Personal Data
We may collect or obtain personal data about you: (i) directly from you (e.g., where you contact us); (ii) in the course of our relationship with you (e.g., if we provide legal advice to you); (iii) when you make your personal data public (e.g., if you make a public post on social media); (iv) when you download, install, or use any of our Apps; (v) when you visit our Sites; (vi) when you register to use any of our services; or (vii) when you interact with any third-party content or advertising on a Site or in an App. We may also receive personal data about you from third parties (e.g., law enforcement authorities).
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of Personal Data, or changes in applicable law. We encourage you to read this policy carefully and to regularly check this page to review any changes we might make to the terms of this Policy.
We may collect personal data about you from the following sources:
Data you provide: We may obtain your personal data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means, or if you provide us with your business card).
Relationship data: We may collect or obtain your personal data in the ordinary course of our relationship with you (e.g., in the course of corresponding with you).
Data you make public: We may collect or obtain your personal data that you choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post).
App data: We may collect or obtain your personal data when you download or use any of our Apps.
Site data: We may collect or obtain your personal data when you visit any of our sites or use any features or resources available on or through a site.
Registration details: We may collect or obtain your personal data when you use, or register to use, any of our sites, apps, or services.
Content and advertising information: If you choose to interact with any third-party content or advertising on a site or in an app, we may receive personal data about you from the relevant third party.
Third party information: We may collect or obtain your personal data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).
(C) Creation of Personal Data
We may also create personal data about you, such as records of your communications and interactions with us, including attendance at events we hold or interviews in the course of applying for a job with us. We may record telephone calls, meetings, depositions, and other interactions in which you are involved, in accordance with applicable law.
(D) Categories of Personal Data we may process
We may process the following categories of personal data about you:
Personal details: given name(s); preferred name; and photograph.
Demographic information: gender; date of birth/age; nationality; salutation; title; and language preferences.
Identifier information: passport or national identity number; utility provider details; bank statements; tenancy agreements.
Contact details: correspondence address; telephone number; email address; and details of your public social media profile(s).
Matter details: details of individuals instructing Privatus Counsel; personal data included in correspondence, transaction documents, evidence, or other materials that we Process in the course of providing services and legal advice.
Attendance records: details of meetings and other events organised by or on behalf of Privatus Counsel that you have attended.
Consent records: records of any consents you may have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).
Payment details: billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; and card expiration date; invoice records; payment records; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of checks.
Data relating to our sites and apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a site; app usage statistics; app settings; dates and times of connecting to an app; and other technical communications information; username; password; security login details; usage data; aggregate statistical information.
Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.
Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or app screens displayed to you, and any interaction you may have had with such content or advertising (including mouse hover, mouse clicks, any forms you complete (including incomplete forms not submitted) and any touchscreen interactions).
Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
(E) Sensitive Personal Data
We may have to process your sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal daaa for any reason, we rely on one of the following legal bases:
Compliance with applicable law: We may process your sensitive personal data where the processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations).
Detection and prevention of crime: We may process your sensitive personal data where the processing is necessary for the detection or prevention of crime (including the prevention of fraud).
Establishment, exercise or defense of legal rights: We may process your sensitive personal data where the processing is necessary for the establishment, exercise or defense of legal rights; or
Consent: We may process your sensitive personal data where we have, in accordance with applicable law, obtained your express consent prior to processing your sensitive personal data (this legal basis is not used in relation to processing that we are legally required to carry out).
(F) Purposes of Processing and Legal Bases for Processing
We process personal data for the following purposes: providing our sites, apps, and services to you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our sites, apps, and services; fraud prevention; and recruitment and dealing with job applications.
(G) Disclosure of Personal Data to third parties.
We may disclose your personal data to the following entities: (i) Legal and regulatory authorities; (ii) our external advisors; (iii) our Processors; (iv) any party as needed in connection with legal proceedings; (v) any party necessary for investigating, detecting or preventing criminal offences; (vi) any purchaser of our business; and (vii) any third party providers of advertising, plugins or content used on our Sites or our apps.
(I) Data Security
We implement appropriate technical and organisational security measures to protect your personal data. Please ensure that any personal data that you send to us are sent securely.
(J) Data Accuracy
We take every reasonable step to ensure that your personal data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
(K) Data Minimization
We take every reasonable step to limit the volume of your personal data that we process to what is necessary.
(L) Data Retention
We take every reasonable step to ensure that your personal data are only retained for as long as they are needed.
(M) Your Legal Rights
Under applicable law, you may have a number of rights, including: (i) the right not to provide your personal data to us; (ii) the right of access to your personal data; (iii) the right to request rectification of inaccuracies; (iv) the right to request the erasure, or restriction of processing, of your personal data; (v) the right to object to the processing of your personal data; (vi) the right to have your personal data transferred to another controller; (vii) the right to withdraw consent; (viii) and the right to lodge complaints with data protection authorities. We may require proof of your identity before we can give effect to these rights.
(N) Cookies and Similar Technologies
(P) Direct Marketing
We may process your personal data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
(Q) Contact Details
If you have any comments, questions, or concerns about data privacy, including the processing of personal data conducted by us, or on our behalf, please contact us.