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Data Protection and Privacy Policy

Responsibility

This Data Protection and Privacy Policy (“Privacy Policy”) is provided by SOL International Ltd (ADGM Commercial Licence No. 000001580 of Office 2473 24 Floor Al Sila Tower Abu Dhabi Global Market Square PO Box 128666 Abu Dhabi, UAE; “SOL International Ltd”, “we”, “us”, “our”), for and on behalf of itself. This Policy has been prepared with reference to ADGM Data Protection Regulations 2021.

We are committed to safeguarding the privacy of the personal information that we process in the course of our business, including the personal information we receive from you (“you” or “your”). 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.  It also sets out your rights in respect of our processing of your personal information.

Please take a moment to read the following information carefully in order to gain a better understanding of our policies and procedures for handling personal data. If you have any queries about our approach to data protection, please contact our Data Protection Officer, as per the contact details set out at the end of this Privacy Policy.

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

Collection of Personal Information

We may collect personal information from you during the course of our business, when you contact us or request information from us, when you instruct us to provide legal services, when you use our website, or as a result of your relationship with any of our personnel or clients.

The personal information that we process includes:

  • Basic details, such as your name, role/title, employer/s, and your contact information (such as your email address, physical address, contact numbers);
  • Identification information to enable us to check and verify your identity (e.g. your birthdate; your passport details), and information collected from publicly available resources to verify the same;
  • Information in respect of the matter on which our legal services are sought;
  • Bank account or other financial information, as relevant to our engagement with you;
  • Relevant information as required by Know Your Client and/or Anti-Money Laundering and/or Counter Finance Terrorism regulations and as part of our client intake procedures. This may possibly include evidence of source of funds, at the outset 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 and/or through the use of online sources;
  • Technical information (including your location, IP address, browser details, traffic data), such as information from website visits (page interaction information, length of visits, etc.);
  • Information in respect of office visits, or meetings and events, including appointment details (e.g. time, location, participants), CCTV images and other photographic or video images;
  • Personal information provided to us by or on behalf of our clients, or generated by us in the course of providing services to them, which may include special categories of personal data;
  • Any other information relating to you which you may provide to us.

We may collect your personal information:

  • As part of our new business intake and client on-boarding or client maintenance activities, and when you seek legal services from us;
  • When you seek employment from us, as part of our new employee on-boarding and maintenance of the employment relationship, or when you engage with our alumni group;
  • When you provide (or offer to provide) services to us, either yourself or on behalf of your employer;
  • When we are acting on a matter where you or your employer are a party to the same;
  • When you interact with our website;
  • When you interact with us in respect of any of our marketing communications or events;

We collect most of this information directly from you, or through your use of our website. However, data may also be collected from a third party source, such as our clients, your employer, other parties to matters in which we are involved, platform operators for technology used in our business (e.g. webinar platforms), regulators or other government authorities, credit reporting agencies, information service providers, or from publicly available records.

The information provided by you may be confidential, and we will maintain such confidentiality and protect your information in accordance with our professional obligations and the relevant applicable law.

Purposes

Whether personal data is received directly from you or from a third party, such information will only be used with prior consent or if another lawful basis upon which to do so exists.

The purposes for which we process your personal information are as follows:

  • Providing legal services to you;
  • Communicating with you in respect of legal developments and the promotion of our legal practice;
  • Managing our business relationship with you (or your organisation), whether in connection with the provision of our legal services, the procurement of your goods and services, or as your employer (or potential or former employer), including processing payments, accounting, auditing, billing and collection and related support services;
  • Complying with our legal obligations, including with respect to legal and regulatory considerations (e.g. anti-money laundering and sanctions checks, audits, enquiries by regulatory authorities);
  • Managing and securing access to our premises and information technology systems, and monitoring the technology side of our operations;
  • Updating contact details to ensure accuracy and relevance using information provided by you, or publicly available information;
  • For any purpose related and/or ancillary to any of the above or any other purposes for which your personal data was provided to us.

The personal data collected will only be used for the intended purpose, unless we reasonably consider that such information must be used for another reason and that reason is in line with the original purpose.

Legal basis to use or process your personal information

It is necessary for us to use and process your personal 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 personal information in such a way to ensure that we provide the Services in the best way that we can.
  • It is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

Cookies

Cookies are small pieces of data that are stored on the computer by the web browser while browsing a website in order for the website to remember the user’s data. Information from cookies may include information relating to your use of our websites, information about your computer (such as IP address and browser type), and demographic data. We use cookies to improve our website.

All web browsers have a system that notifies you when you receive a new cookie and tells you how to reject new cookies or disable cookies altogether (if you wish to do so).

Sharing your Personal Information

We may disclose your personal information to the following recipients as necessary:

  • Government or regulatory authorities
  • Professional indemnity or other relevant insurers.
  • Professional advisers such as lawyers and accountants.
  • Regulators/Corporate registries/Tax Authorities
  • Third party service providers to assist us with client insight analytics, such as Google Analytics.
  • Third parties to whom we outsource certain services such as, documents processing and translation services, IT Systems or software providers, document and information storage providers.
  • Third parties engaged in the course of services we provide to clients such as counsel, arbitrators, mediators, clerks, witnesses, courts, opposing parties and their lawyers, document review platforms and experts.

This list is non-exhaustive and there may be other examples where we might need to share your personal information with other parties in order to provide the services as effectively as possible.

We take photographs and video of our events, and this may result in your image being captured and used in the course of reporting on the event (e.g. via social media or other means); we will draw this to your attention in materials relating to the specific events.

In relation to any other disclosures to third parties, we will only do so where you have given your consent, where we are required to do so by law, or where it is necessary for the purpose of or in connection with legal proceedings or in order to exercise or defend legal rights. We do not sell, rent, distribute, or otherwise make, personal information commercially available to any third party.

Cross-Border Transfer of your Information

It may sometimes be necessary for us to share your personal information with associated professional services firms around the world, who provide services to us or on our behalf (including data storage facilities or online storage located within or outside the United Arab Emirates, which may be operated by independent service contractors). This will entail a transfer of personal information from within the Abu Dhabi Global Market to recipients outside the ADGM, and vice versa.

The level of personal information protection in the various jurisdictions in which we operate varies, and in some instances may not provide an adequate level of protection from an international perspective. To address this, we have procedures and safeguards in place to ensure the protection of personal information. These procedures include contractual obligations to ensure that all such entities safeguard your personal information and use it only for the purposes that we have specified and communicated to you. When we transfer your information to other countries, we will use, share and safeguard that information as described in this Privacy Policy.

How long we keep your Personal Information

We will retain your personal information for the length of time needed to fulfil the purposes for which it was collected, unless we specifically agree a longer retention period with you, or a longer retention period is required or permitted by law in accordance with our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.

Your Rights

Various rights may be available to you, depending on the circumstances and the applicable law.

  • Right to withdraw consent: When personal information is processed on the basis of consent, you have the right to withdraw that consent at any time, although such withdrawal will not affect the lawfulness of data processed prior to such withdrawal;
  • Right of access: Upon request, we will provide confirmation in respect of personal information being processed and, if necessary, will provide you with a copy of that personal information. Additional copies may also be provided upon payment of a reasonable fee;
  • Right to rectification: In case any personal information held by us is inaccurate or incomplete, you are entitled to put forth a request to have such information rectified. If we have shared your personal information with third parties, we will inform them of such rectification;
  • 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 you have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly;
  • Right to restrict processing: You can put forth a request to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you challenge the accuracy of that personal information or you make an objection to us. In the event you are entitled to such restriction and if we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so;
  • Right to data portability: You have the right, in certain circumstances, to obtain personal information you have provided us with (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;
  • 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 establish persuasive legal grounds for the processing;
  • Right to lodge a complaint: If you believe that your data protection rights may have been breached, you may lodge a complaint with the relevant data protection authority (e.g. the ADGM Commissioner of Data Protection)
  • 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 establish persuasive legal grounds for the processing;
  • Right to lodge a complaint: If you believe that your data protection rights may have been breached, you may lodge a complaint with the relevant data protection authority (e.g. the ADGM Commissioner of Data Protection)

If you would like to exercise any of the above rights, or any other rights available to you pursuant to the applicable law, please contact our Data Protection Officer using the contact details set out below.

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.

Information Security

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

All our employees and consultants who have access to, and/or are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.

Changes to this Privacy Policy and your duty to inform us of changes

We may from time to time make changes to this Privacy Policy. Where these are likely to be material, we will communicate these in advance. Otherwise, these will become effective once the amended Privacy Policy is posted on our website. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Please check back regularly to keep informed of updates to this Privacy Policy.

It is important that the personal data we hold about you is accurate and updated. Please keep us informed if your personal data changes during your relationship with us.

Contact Details

Our Data Protection Officer oversees compliance with data protection within SOL International Ltd. If you have any questions about this Privacy Policy, or our processing of your personal data, please contact our Data Protection Officer using the contact details set out below:

Data Protection Officer
Sarah Malik

SOL International Ltd
Office 2473 24 Floor Al Sila Tower
Abu Dhabi Global Market Square PO Box 12866
Abu Dhabi UAE
Email: info@sol-intl.com
Telephone: +971 2 694 8695

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