Privacy Policy

Your privacy is important to us. This Privacy Policy explains how we handle and treat your data when you (i) register or visit our site, samuel-samuel.com or associated sites or pages (the “Site”) or (ii) engage with us to use theproducts or services that Samuel & Samuel provides (our “Services”). It also includes information about individuals whose personal information we mayprocess as a result of providing the Services to third parties.

1. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) explains our approach to any personal information that we collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. It also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of your personal information that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services and/or to understand how your personal information may be processed by us as a result of providing the Services to third parties. Please take a moment to read and understand it.

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us.

2. WHO WE ARE AND WHAT WE DO

Samuel & Samuel is a legal consultancy operating as a separate free zone limited liability company, and who partners with individual law firms globally in Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Colombia, France, Gibraltar, India, Indonesia, Ireland, Italy, Japan, Malaysia, Mexico, Monaco, Netherlands, Peru, Philippines, Poland, Qatar, Russia, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Thailand, United Arab Emirates, United Kingdom, United States and Vietnam. We provide our Services in accordance with the relevant laws of the jurisdictions in which we operate.

Samuel & Samuel FZ-LLC is the data controller responsible for your personal information processed via the Site.

3. Contact Us

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an email to legal@samuel-samuel.com.

4. THE PERSONAL INFORMATION WE COLLECT

We may collect personal information from you in the course of our business, including through your use of our Site, when you contact or request information from us,when you engage our legal or other services or as a result of your relationship with one or more of our staff or clients.

Our primary goal in collecting personal information from you is to help us:

• verify your identity;
• deliver our Services;
• improve, develop and market new Services;
• carry out requests made by you on the Site or in relation to our Services;
• investigate or settle inquiries or disputes;
• comply with any applicable law, court order, other judicial process, or the requirements of a regulator;
• enforce our agreements with you;
• protect the rights,property or safety of us or third parties, including our other clients and users of the Site or our Services; and
• use as otherwise required or permitted by law.

To undertake these goals, we may process the following personal information:

If you are a visitor to the Site

• Name and job title;
• Contact information including the company you work for, email address and social media account where appropriate;
• Demographic information such as your address, preferences and interests; and
• Other information relevant to the provision of Services.

If you are an individual client in receipt of our Services or prospective individual client:

• Name and job title;
• Contact information including the company you work for and email address, where provided;
• Payment information;
• Information that you provide to us as part of us providing the Services to you, which depends on the nature of your instructions to us;
• Relevant information as required by Know Your Client and/or Anti-Money Laundering regulations and as part of our client in take procedures. This may possibly include evidence of source of funds, at the out set of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from you or through the use of online sources or both;
• Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs; and
• Other information relevant to provision of Services.

Samuel& Samuel is primarily engaged by corporate entities and as such those clients are not data subjects. However, in connection with instructions received from such clients, personal information may be provided to us (e.g.personal information relating to any of our corporate clients’ or prospective clients’ officers or personnel, any opponent or vendor or purchaser or personal information relating to their legal advisors or personnel, as relevant or similar).

If you are an individual whose personal information is processed by us as a result of providing the Services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the Services provided. This may include personal information relating,without limitation, to any of our corporate clients’ or prospective clients’officers or personnel, any opponent or vendor or purchaser personal information including personal information relating to their legal advisors, other advisors or personnel as relevant or similar.

We might also need to process personal information in relation to other third parties instructed either by our own clients or other persons or companies involved with us providing the Services to our client (for instance other law firms, experts etc.).

This is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of a law firm providing legal services.

For clients and prospects, we also collect information to enable us to market our products and Services which may be of interest to you. For this purpose we collect:

• Name and contact details;
• Other business information such as job title and the company you work for;
• Areas or topics that interest you; and
• Additional information may be collected such as events you attend and if you provide it to us, dietary preferences which may indicate data about your health or religious beliefs.

5. HOW WE USE YOUR PERSONAL INFORMATION

We may use your information for the following purposes:

Fulfilment of Services. We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services to enable us to perform the Services. Please note also that our Terms of Business apply when we provide the Services.

• Our legal basis. It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way as to ensure that we provide the very best client service we can to you or others.

Client services. Our Site uses various user interfaces to allow you to request information about our Services including electronic enquiry forms. Contact information may be requested in each case, together with details of other personal information that is relevant to your Service enquiry. This information is used to enable us to respond to your requests.

• Our legal basis. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.

Business administration and legal compliance. We use your personal information for the following business administration and legal compliance purposes:

• to comply with our legal obligations (including any Know Your Client or Anti-Money Laundering or Anti-Bribery, conflicts or similar obligations including, but without limitation, maintaining any required insurance);
• to enforce our legal rights;
• to protect the rights of third parties; and
• in connection with a business transaction such as a merger, or a restructuring, or sale.
• Our legal basis. Where we use your personal information in connection with a business transaction, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

Marketing communications. We carry out postal marketing and email marketing using your personal information. We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section below for more details of the information collected and how it is collected) to send you marketing communications. We will only send you marketing communications where you have consented to receive such marketing communications, or where we have a lawful right to do so.

• Our legal basis. It is in our legitimate interest to use your personal information for marketing purposes.

Client insight and analysis. We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

• an IP address to monitor Site traffic and volume;
• a session ID to track usage statistics on our Site; and
• information regarding your personal or professional interests, demographics, experiences with our products and contact preferences;
• our web pages contain “cookies”, “web beacons” or “pixel tags” (“Tags”). Tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and to collect other types of aggregate information. Please see our Cookie Policy for further information.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our users like to see.

We also use this information for marketing purposes (see the marketing section above for further details).

• Our legal basis. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details, where available.

6. SHARING YOUR PERSONAL INFORMATION

Samuel & Samuel FZ-LLC is a legal consultancy operating as a free zone limited liability company, and any information that we collect or that you provide to us may be shared and processed by any Samuel & Samuel entity.

We may also share personal information with a variety of the following categories of third parties as necessary:

• Our professional advisers such as lawyers and accountants;
• Government or regulatory authorities;
• Professional indemnity or other relevant insurers;
• Regulators/tax authorities/corporate registries;
• Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers;
• Third parties engaged in the course of the services we provide to clients such as counsel, arbitrators, mediators, clerks, witnesses, cost drafts men, court, opposing party and their lawyers, document review platforms and experts such as tax advisors or valuers;
• Third party service providers to assist us with client insight analytics, such as Google Analytics; and
• Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.

7. OUR USEOF COOKIES AND SIMILAR TECHNOLOGIES

OurSite use certain Tags, log files and other technologies of which you should beaware. Please see our Cookie Policy to find out more about the cookies we useand how to manage and delete cookies.

8. THIRD PARTY CONTRACTORS AND OTHER CONTROLLERS

As mentioned above, we may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers, who will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any such sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

Further, we may appoint external data controllers where necessary to deliver the Services (for example, but without limitation, accountants, legal counsel or other third party experts including but without limitation other Samuel & Samuel entities). When doing so we will comply with our legal and regulatory obligations in relation to the personal information, including but without limitation, putting appropriate safeguards in place.

Our legal basis

It is necessary for us to perform our obligations in accordance with any contract that we may have with you.

It is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.

9. TRANSFERRING YOUR DATA

In order to provide the Services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it.

If you are based within the European Economic Area (EEA), please note that where necessary to deliver the Services we will transfer personal information to countries outside the EEA (including to Samuel & Samuel FZ-LLC and other Samuel & Samuel entities).

In all such cases, we ensure we comply with our legal and regulatory obligations in relation to personal information, including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

10. LENGTH OF RETENTION

For visitors to the Site, we may retain relevant personal information for at least three years from the date of our last interaction with you and in compliance with our obligations under various data protection legislation around the world, or for longer if we are required to do so according to our regulatory obligations or professional indemnity obligations.

For Service provision to any client, we will retain relevant personal information for at least seven years from the date of our last interaction with that client and in compliance with our obligations under various data protection legislation around the world, or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.

If personal information is only useful for a short period (for example, for specific marketing campaigns), we may delete it following such short period.

11. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information provided to us secure and we have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.

All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.

12. ACCESSING YOUR INFORMATION AND YOUR OTHER RIGHTS

You have the following rights in relation to the personal information we hold about you:

• Your right of access. If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification. If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you with whom we’ve shared your personal information so that you can contact them directly.
• Your right to erasure. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you with whom we’ve shared your personal information so that you can contact them directly.
• Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you with whom we’ve shared your personal information so that you can contact them directly.
• Your right to data portability. You have the right, in certain circumstances, to obtain personal information you’ve provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
• Your right to object. You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing purposes.
• Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant supervisory authority.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

13. COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS

The Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as Samuel & Samuel has no control over information that is submitted to, or collected by, these third parties.

14. CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.