Personal data refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (the “Personal Data”).
Responsibility of your Personal Data
lecocqassociate Group (as defined below) is responsible for your Personal Data that it processes. lecocqassociate Group consists of four international offices: lecocqassociate, a boutique law firm with its office in Geneva, Switzerland; lecocqassociate ltd, a regulatory advisory practice in Valletta, Malta, lecocqassociate (DIFC) Ltd, a structuring advisory practice located in the DIFC (Dubai International Financial Centre) and lecocqassociate legal ltd, a legal consultancy situated in the ADGM (Abu Dhabi Global Market), (collectively, the "lecocqassociate Group" and individually, the “lecocqassociate Entity”).
Specifically, your data will be controlled by the lecocqassociate Entity that is providing services or communication to you in your jurisdiction or managing the website, whichever may be applicable to you. However, please note that your Personal Data can be transferred within the lecocqassociate Group, for the provision of services to you.
Type of Personal Data being collected
The Personal Data that we collect about you may include:
- Contact information, such as your name, postal address, including your home address (where you have provided this to us), business address, telephone number, mobile phone number and email address;
- Information collected from publicly available resources, integrity databases, risk screening tools and credit agencies;
- If legally required for compliance purposes such as for client due diligence and any information about relevant and significant litigation or other legal proceedings against you or a third party related to you and interaction with you which may be relevant for antitrust purposes;
- Other Personal Data only where it is relevant to the services that lecocqassociate Group provides;
- Details of your visits to our premises, or calls made, or correspondence sent to us; and
- Personal Data about your membership in a professional or trade association or union, health Personal Data, details of dietary preferences (relevant to events in which we invite you) and details of any criminal record you may have.
Collection of your Personal Data
We may collect Personal Data about you in a number of circumstances, including:
- When you seek any type of advice from us (e.g. legal, regulatory and/or consultancy);
- When you browse, make an enquiry or otherwise interact on our website; or
- When you offer to provide or provide services to us.
In some circumstances, we collect Personal Data about you from a third-party source. For example, we may collect Personal Data from your organisation, other organisations with whom you have dealings, government agencies, credit reporting agency, an information or service provider or from a publicly available record. In such cases, the purposes for the collection of your Personal Data from a third-party source will still be the permitted purposes (as defined below) mentioned in this Privacy Notice.
The requirement of providing us with your Personal Data and the consequences in the case you do not provide such
By way of an example, as a result of not receiving your consent, we may not be able to:
- provide any service required from lecocqassociate Group; and/or
- provide you with access to a web offering or newsletter; and/or
- carry out a legally required compliance screening.
In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant Personal Data. Moreover, in the course of our relationship, your decision not to provide us with ongoing personal information as might be required for anti-money laundering purposes, might lead to lecocqassociate Group having to terminate the relationship with you. We will notify you accordingly of the purposes for which your Personal Data is being required and whether there will be any detrimental effects in the case that you do not provide such Personal Data.
Purpose of processing your Personal Data
We may use your Personal Data for the following purposes only (the "Permitted Purposes"):
- Managing and administering any request for a service made by you or by your organisation;
- Compliance with our legal and regulatory obligations (such as record keeping obligations), compliance screening or recording obligations (for example anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for compliance purposes;
- To analyse and improve our services and communications to you in relation to the services which we provide to you or to your organisation;
- Protecting the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
- For monitoring and assessing compliance with our internal policies and standards;
- To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
- To comply with court orders and exercises and/or defend our legal rights; and
- For any purpose related and/or ancillary to any of the above or any other purpose for which your Personal Data was provided to us.
Where you have given us your consent, we may process your Personal Data also for the following purposes:
- Communicating with you through the channels you have approved to keep you up to date on the latest legal developments, announcements, and other information about our services, (including newsletters and other information) as well as lecocqassociate Group events and projects;
- Customer surveys, marketing campaigns, market analysis, or other promotional activities or events; or
- lecocqassociate Group may also undertake business development and marketing activities. In this case, where we rely on your consent for such purposes, you have the right to object at anytime to the processing of your Personal Data for such purposes.
We will not use your Personal Data for taking any automated decisions affecting you or creating profiles other than described above.
Depending upon the specific Permitted Purposes we use your Personal Data, we may process your Personal Data on one or more of the following legal grounds:
- Because processing is necessary for the performance of your instruction or other contract with you or your organisation and for us to be able to provide you with the requested service;
- To comply with our legal and/or regulatory obligations which become applicable to lecocqassociate Group from time to time;
- Because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your Personal Data in managing our business including legal, personnel, administrative and management purposes and for the prevention and detection of crime, provided that such interests are not overridden by your interests or your fundamental rights and freedoms.
In addition, the processing may be based on your consent where you have expressly given that to us (as described above).
Recipients of your Personal Data
We may share your Personal Data in the following circumstances:
- Between the lecocqassociate Group on a confidential basis where required for the purpose of providing the respective service that you have mandated us for e.g. legal advice, regulatory advice, consultancy and for other business purposes related to you and your business;
- If you are a client of lecocqassociate Group, or are contracted to or are an agent of a client of lecocqassociate Group, we may disclose your Personal Data to:
- Partners, senior associates, associates, support staff, other professionals and specialists, consultants or experts engaged in your matter; or
- Foreign law firms, regulatory advisors, consultants and professional service providers for the purpose of obtaining foreign advice in relation to your matter;
- World Check, for us to assess your online reputation
- If we have collected your Personal Data in the course of providing legal services, regulatory services or consultancy services to any of our clients, we may disclose it to that client, and where permitted by law to others for the purpose of providing those services;
- We may disclose your contact details on a confidential basis to third-parties for the purposes of collecting your feedback on our service provision, to help us measure our performance and to improve and promote the services we offer to our clients;
- We may share your Personal Data with companies providing services for money laundering checks and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such Personal Data is shared;
- We may share your Personal Data with any other third-party providing services to the lecocqassociate Group, including, information technology, as well as professional service providers, accountants, bookkeepers and payroll entities.
- We may share your Personal Data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal claim, or for the purposes of a confidential alternative dispute resolution process;
- We may also instruct service providers within or outside of lecocqassociate Group, domestically or abroad, to process Personal Data for the Permitted Purposes on our behalf and in accordance with our instructions only. lecocqassociate Group will retain control over and will remain fully responsible for your Personal Data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your Personal Data when engaging such service providers;
- We may also use aggregated Personal Data and statistics for the purpose of monitoring website usage in order to help us develop our website and the services which we offer;
Otherwise, we will only disclose your Personal Data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
International transfer of your Personal Data
lecocqassociate Group has offices in Switzerland, Malta, Dubai and Abu Dhabi. Hence, we may transfer your Personal Data outside of the European Union (the “EU”) and/or the European Economic Area(the “EEA”) if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the Swiss Federal Act on Data Protection as well as the General Data Protection Regulation (EU) 2016/679 (“GDPR”) or other relevant laws (as applicable). This includes entering into the EU Standard Contractual Clauses which are available here (if applicable).
All our offices throughout the world will at all times ensure a level of data protection at least as protective as that required in the Switzerland and EEA (as applicable). We will also require our agents, consultants and subcontractors and others who are outside the EEA and Switzerland (as applicable) and to whom we transfer your personal data to ensure a similar level of data protection.
When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data. Such transfer occurring to countries outside of the EEA is only carried out if the EU has approved such third countries as having equivalent data protection laws in place.
You may contact us anytime using the contact details below if you would like further information on the above.
Personal Data about third parties which you provide to us
Security measures for the safekeeping of your Personal Data
We will take appropriate technical and organisational measures to keep your Personal Data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Data. Personal Data may be kept on our personal data technology systems, those of our service providers or in paper files.
Updating your Personal Data
If any of the Personal Data that you have provided to us changes, or if you wish to cancel any request you have made to us, or if you become aware that we have any inaccurate personal data about you, please let us know by contacting us using the contact details mentioned hereunder.
We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.
We will, in particular, retain your Personal Data where required for lecocqassociate Group to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled, which may vary according to the applicable law.
Otherwise, your Personal Data will be deleted in the following circumstances:
- when it is no longer reasonably required for the Permitted Purposes; or
- when you withdraw your consent (where applicable); and
- when we are not legally required or otherwise permitted to continue storing such data.
You have various rights in relation to your personal information, including the following:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent to our processing of your Personal Data at anytime, if relevant. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason (other than consent) for doing so;
- in some circumstances, the right to receive some Personal Data in a structured,commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided to us and only where the GDPR applies to you;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data in certain circumstances.Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
- the right to object to, and the right to request that we restrict the processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, the processing of your Personal Data but we are legally entitled to continue processing your Personal Data and/ or to refuse that request; and
- the right to lodge a complaint with the local data protection regulator if you think that any of your rights have been infringed by us.
If you wish to do any of the above, please use the contact details provided below.
We may request proof of identification to verify your request. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your Personal Data, and for any additional copies of the Personal Data you request from us.
We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one (1) month after of receipt of your request. In exceptional cases, we may extend this period by two(2) months and we will tell you why.
If you are not satisfied with our response, you may take your complaint to the relevant data protection authority, which may be the data protection authority of the country of your habitual residence, place of work or place where the alleged infringement had happened.
In case the GDPR applies to you and you wish to address the Maltese Information and Data Protection Commission; you can contact it at: https://idpc.org.mt/en/Pages/contact/complaints.aspx
For any other authority, you can find the appropriate at the following link: https://edpb.europa.eu/about-edpb/board/members_en
If you would like to contact us with any queries or comments, please contact our Data Protection Officers by using the below contact details:
Swiss Urban Factory
The Regulatory Suite
5 St. Frederick Street Valletta
Malta VLT 1470
Email address: firstname.lastname@example.org
Contact Number: +35622482910
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