A. WHO ARE WE?
The websites at lawyers-auditors.com and all associated domains (our “Websites”) are owned and operated by De DE MICCO & FRINDS SL, Palma de Mallorca, Spain for the benefit of all Micco & Friends member Firms and their connected businesses (the “Micco & Friends Offices”).
DE MICCO & FRIENDS is a data controller of personal Information (as defined below) collected on the Websites. Where DE MICCO & FRIENDS shares Personal Information with the DE MICCO & FRIENDS Offices, the DE MICCO & FRIENDS Offices are also data controllers as explained in this Privacy Notice.
DE MICCO & FRIENDS has its head office at: C. Llorenc y Vicens 3, 07002 Palma de Mallorca, Spain. The contact email address for DE MICCO & FRIENDS is firstname.lastname@example.org. Its contact telephone number is: +34 871 955 077, its TAX ID is: ESB57925828.
This Privacy Notice describes how we collect, use and otherwise handle “Personal Information” that you provide or make available to us, or that we collect from you, when you use our Websites, and explains the circumstances in which we may transfer this to others.
“Personal Information” is information relating to you, which can be used to personally identify you (either directly or indirectly).
Our Privacy Notice must be read together with any other legal notices or terms and conditions available on other pages of our Websites.
As DE MICCO & FRIENDS is an international legal practice, operating from multiple jurisdictions, various country-specific requirements may apply to your use of our Websites. You can view country-specific privacy information as part of this Privacy here.
C. HOW, WHEN AND WHY DO WE COLLECT AND USE PERSONAL INFORMATION?
1. Information that we collect
The types of information that we may collect from you, depending on how you use our Websites include:
- your name;
- your email address;
- your address (business and personal);
- your landline and mobile telephone numbers (business and personal);
- any other information that you choose to provide to us when filling out a contact form on our Websites;
- your geographic location (country/territory where you are living and/or working);
- your job title, role and the name of your employer;
- the industry sector in which you work;
- the country or countries, industry sector(s) and area(s) of law in respect of which you wish to receive information or services
- the content of the delivered text, request from you
- your IP address
- your delivered or on our servers uploaded files and data
- your C.V. and covering letter (where you apply for a vacancy with us on our Websites).
2. How we use your Personal Information
Contact Forms - we may collect your Personal Information, which you choose to provide when you fill in forms on our Websites, including the information set out in a.-m. above. We may use this Personal Information to respond to your queries, and/or provide the services and/or information that you have requested.
Online Portals - if you choose to subscribe to on of our client portals, we use Personal Information that you provide during the subscription process to send you relevant content by email. This will consist of information on legal, tax and business issues that are relevant to your preferences. We will also tell you about our news, events and seminars. You have the option to receive invitations to our events. If you want to receive such invitations you can let us know by ticking the relevant box on the subscription form.
Portal opt-out - you are entitled to opt-out from receipt of portals communications at any time.
Our Business Purposes - we may also use your Personal Information for our business purposes such as:
- record keeping, statistical analysis, internal reporting and research purposes;
- to ensure network and information security;
- to inform you about new services;
- to inform you about new partners and strategic alliances
- to notify you about changes to our services;
- to investigate any complaint, you make;
- to provide evidence in any dispute or anticipated dispute between you and us;
- to customise various aspects of our Websites to improve your experience;
- to host, maintain and otherwise support the operation of our Websites;
- for the detection and prevention of fraud and other criminal offences and for risk management purposes;
- for business and disaster recovery (e.g. to create back-ups);
- for document retention/storage;
- for database management;
- to protect the rights, property, and/or safety of DE MICCO & FRIENDS, its personnel and others; and
- to ensure the quality of the services we provide to our users.
In addition, we may use your Personal Information for further specific purposes made clear at the point of collection on particular pages of our Websites.
If you choose not to provide Personal Information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information. Aside from this, your visit to our Websites will remain unaffected.
3. Legal grounds for collection and use of Personal Information
We ask for your consent to process your personal information in relation to our portals and in some cases for recruitment purposes (where this is made clear to you at the point where you provide your information). In other cases, we process your personal information where we need to do so:
- to comply with our legal and regulatory obligations;
- for our legitimate interests in:
- responding to your queries;
- providing services and/or information to you;
- recruiting personnel (except in cases where we ask for your consent as mentioned above); and
- our internal business purposes, as set out in 2. above.
We consider that the risk to your data protection rights in connection with Personal Information that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.
If you would like to find out more about the legal grounds on which we process your Personal Information for a particular purpose you can contact us here.
5. Information from other sources
Where permissible under applicable local laws, we may combine information that you have provided to us with other information that we already hold about you and which we have collected for a compatible purpose.
D. HOW AND WHEN DO WE SHARE INFORMATION WITH THIRD PARTIES?
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is adequately protected. Details about how we share Personal Information with third parties is set out below:
1. Google Analytics
Our Websites use Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics works using cookies.
Google Analytics cookies collect your IP address, however because IP anonymisation is used on our Websites, your IP address will be shortened (and therefore anonymised) as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics.
The anonymisation process takes place within the European Union or the European Economic Area, except in exceptional cases, where your full IP address may be sent to a Google server in the U.S.A. and shortened there.
We use the information collected by Google Analytics cookies to find out about how visitors use our Websites.
The IP address sent by your browser in connection with Google Analytics will not be combined by Google, with other data.
You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
2. Sharing within DE MICCO & FRIENDS and to Service Providers
DE MICCO & FRIENDS shares your Personal Information with DE MICCO & FRIENDS Offices and associated partners:
- if you ask that we should do so in an online form;
- if you tick the relevant box on the portals and online registration forms, in order to receive information about services and events provided by DE MICCO & FRIENDS Offices; or
- where we need to do so in order to provide the services or information that you have requested.
When a DE MICCO & FRIENDS Office would like to use your Personal Information for a new purpose, they will let you know about this first.
We also share your Personal Information with our third party service providers based in the European Economic Area (“EEA”) who we engage to provide support services in relation to our Websites for the purposes of: hosting and maintaining our Websites; providing data storage; assisting us with database management, and in order to assist us with related tasks or processes.
All of our service providers are bound by written contract to process Personal Information provided to them only for the purpose of providing the specific service to us and to maintain appropriate security measures to protect your Personal Information.
3. Sharing with other third parties
We share your Personal Information with:
- our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
- any other third party if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or to protect the rights, property and/or safety of DE MICCO & FRIENDS, our personnel or others;
- any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a search warrant or court order or acting in accordance with an applicable law or regulation; or
- investors and other relevant third parties in in the event of an actual potential sale or other corporate transaction related to DE MICCO & FRIENDS.
Our Websites provide sharing buttons that you can click on in order to share content from our Websites on social media channels, e.g., Facebook. We do not use these buttons to share your Personal Information with social media providers. When you click on a sharing button the relevant social media provider will gather Personal Information directly from you. Please read the privacy notice of any social media provider with which you intend to share content before clicking on the corresponding sharing button.
E. INTERNATIONAL TRANSFERS
The transfer of your Personal Information to and between DE MICCO & FRIENDS Firms as described in this Privacy Notice, may involve your Personal Information being sent outside of the EEA, to locations that may not provide the same level of protection as those where you first provided the information.
However, we will only transfer your Personal Information outside of the EEA:
- where the transfer is to a place, or by a method or in circumstances that is regarded by the European Commission as providing adequate protection for your Personal Information. For example, where we have put in place standard data protection clauses adopted by the European Commission; or
- the above does not apply but we are still legally permitted to do so, for example if the transfer is necessary for the establishment, exercise or defence of legal claims.
You can request further detail about the safeguards that we have in place in respect of transfers of Personal Information outside of the EEA and where applicable a copy of the standard data protection clauses that we have in place, by contacting us at email@example.com.
F. HOW LONG DO WE STORE PERSONAL INFORMATION?
It is our policy to retain your Personal Information for the length of time required for the specific purpose or purposes for which it was collected. However, we may be obliged to store some Personal Information for a longer time, taking into account factors including:
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- (potential) disputes and
- guidelines issued by relevant data protection authorities.
Whilst we continue to process your Personal Information, we will ensure that it is treated in accordance with this Privacy Notice. Otherwise, we securely erase your information once this is no longer needed.
If you would like to find out how long we keep your Personal Information for a particular purpose you can contact us here.
Our Websites are hosted on servers in the EEA, ASIA, USA and UAE. We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorised persons. Information storage is on secure computers in a locked and certified information centre and information is encrypted wherever possible. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure we cannot guarantee the security of your information transmitted to our Websites.
We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make Personal Information commercially available to any third party, except that we may share information with our associated partners, service providers for the purposes set out in this Privacy Notice. We will maintain the confidentiality of and protect your information in accordance with our Privacy Notice and all applicable laws.
I. YOUR RIGHTS
The following section explains your rights. The various rights are not absolute and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection laws. Nothing in this Privacy Notice is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws.
1.The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this Privacy Notice.
2. The right of access
You have the right to obtain a copy of your Personal Information (if we are processing it), and other certain other information (similar to that provided in this Privacy Notice) about how it is used.
3. The right to rectification
You can ask us to take reasonable measures to correct your Personal Information if it is inaccurate or incomplete. E.g. if we have the wrong name or address for you.
4. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Information where there’s no compelling reason for us to keep using it or its use is unlawful. This is not a general right to erasure; there are exceptions, e.g. where we need to use your Personal Information in defence of a legal claim.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your Personal Information when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You have rights to obtain and reuse certain Personal Information for your own purposes across different organisations.
7. The right to object
You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us or by a third party. We will be allowed to continue to process your Personal Information if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise or defence of legal claims.
J. HOW TO CONTACT US
If you wish to request further information or exercise any of the above rights, or if you are unhappy with how we have handled your Personal Information, contact us here: firstname.lastname@example.org. Please provide as much information as possible to help us identify the information you are requesting, the action you are wanting us to take and why you believe this action should be taken.
Before assessing your request, we may request additional information in order to identify you. If you do not provide the requested information and, as a result we are not in a position to identify you, we may refuse to action your request.
We will generally respond to your request within one month of receipt of your request. We can extend this period by an additional two months if this is necessary taking into account the complexity and number of requests that you have submitted.
We will not charge you for such communications or actions we take, unless:
- you request additional copies of your Personal Information undergoing processing, in which case we may charge for our reasonable administrative costs, or
- you submit manifestly unfounded or excessive requests, in particular because of their repetitive character, in which case we may either: (a) charge for our reasonable administrative costs; or (b) refuse to act on the request.
If you are not satisfied with our response to your complaint or believe our processing of your Personal Information does not comply with data protection law, you can make a complaint to the relevant EU data protection authority where you are located. The contact details for each EU data protection authority can be found here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
We may make minor changes to our Privacy Notice. When we make these changes, we will publish the updated Notice on our Websites. If we make any significant changes, we will take additional steps to inform you of these.
De Micco & Friends, May 2018