Date: September 18, 2018
Vision and Scope
Data Controller and Data Protection Officer:
Arzinger & Partners Limited Liability Company
Attn: Data Protection Officer
office 36, 12 Sovetskaya str., Minsk, 220030 Belarus
Collection and Use of Your Personal Data
Personal data means any information relating to you that identifies you or could reasonably be used to identify you, and that is recorded in any form. It includes your name (in English and native languages), title, gender, citizenship, date of birth, contact details such as email address(es), postal address(es), phone number(s), current job title and employer, any attachments (such as request for proposal).
Arzinger, as Data Controller, collects personal data from different sources. Most of our data will come from you, for example when you:
- Enquire about our Services or ask us a question;
- Email or get in contact with us in some way (including by providing your business cards, documents for assessment and analysis, complete forms, or complete surveys):
- Communication with us through corporate pages on Facebook or LinkedIn.
Additionally, we may collect and process your personal data from the following publicly available sources such as internet searches and press sources, including media monitoring, provided collection of the data is necessary and relevant to the performance of the request which you submit to us and we are allowed to do so by national laws (“direct search”): LinkedIn, Facebook, Twitter and other social media platforms, Google, Xing, Telegram.
Before making a final decision to cooperate with you, we may collect and process information relating to potential case or project in order to satisfy ourselves that there is no conflict of interest with our current or previous client. We seek to ensure that our information collection and processing is always proportionate. Background checks may be carried out by a background check provider.
How do we use your information?
We may use your personal data for purposes including (but not limited to) the following:
- Fulfilment of Services. We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or by other means to enable us to perform the Services.
- Client services. Our Site uses various user interfaces to allow you to request information about our Services including electronic enquiry forms and a telephone enquiry service. 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 in order to enable us to respond to your requests.
- 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 regulatory insurance);
- to enforce our legal rights;
- to protect the rights of third parties;
- in connection with a business transaction such as a merger, or a restructuring, or sale; and
- for transfer to the appropriate state bodies in cases when such transfer is required by the legislation of the Republic of Belarus.
- Recruitment. We use your personal information for the following recruitment purposes to assess your suitability for any position for which you may apply at Arzinger including partner level positions, associate positions, training contract or summer placements and also any business support or services role whether such application has been received by us online, via email or by hard copy or as an in-person application.
- Marketing communications. We carry out the following marketing activities using your personal information:
- Postal marketing
- Email marketing
We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services 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.
- Client insight and analysis
We analyze 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.
- an IP address to monitor Site traffic and volume;
- a session ID to track usage statistics on our Site;
- 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 collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and the relevant Tag.
In some of our email messages, we use a “click-through URL” linked to certain website administered by us or on our behalf.
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).
Purposes of Processing Your Personal Data
We process your personal data mainly as part of our legitimate business interests. However, depending on the personal data we are collecting, we may process your data under one or more of these other legal reasons:
- when we have to comply with the law or have a legal duty or obligation;
- when we have your consent to use your information;
- to fulfil a contractual obligation.
What is ‘legitimate interests’ and how does it apply to you?
A legitimate interest is where we believe that we need to process your data to pursue a particular purpose and that it would be fair for us to do so. You still have the right to limit or stop processing that has happened.
Transfer of Your Personal Data
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 from 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 draftsmen, 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, Yandex.Metrika;
- 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.
In such case, Arzinger guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses with such third parties.
Security for Your Personal Data
Arzinger uses appropriate administrative, technical, personnel, legal and physical measures to protect your personal data. Hard copies are kept in locked filing cabinets with only certain authorized individuals having access to the information. All electronic data are kept secure on corporate drives with only select authorized individuals having access to the information. Your personal data are also protected through confidentiality undertakings entered into by all persons processing your personal data.
Keeping your information
We retain your personal information for as long as is required depending on your relationship with us and the Services we are providing to you. We will also keep your personal data for as long as may be required by law, for example immigration records must be kept for ten years.
Once your personal data is no longer required, we will ensure that it is deleted securely. In some cases we may retain a very limited amount of data for archiving purposes or to ensure that we can exclude you from further communications if necessary.
If you have any questions about how long we keep your personal data for, please contact us for more information regarding specific categories of personal data.
Use of Third-Party Service Providers
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. Arzinger diligently selects such service providers and enters into written agreements with them ensuring that such providers (i) have adopted adequate data protection and security measures to safeguard your personal data; (ii) only use your data as instructed by Arzinger and for no other purposes; and (iii) store your personal data only within the terms of the agreement. Each third-party service provider guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses.
Your Privacy Rights
You have the right (i) to request from us access to your personal data as well as the right to data portability; (ii) to request from us rectification of your personal data; (iii) to object to the processing; and (iv) to request from us erasure of your personal data. If you would like to exercise any of your rights, please submit the relevant request to firstname.lastname@example.org.
You also have the right to lodge a complaint with a supervisory authority.