Delta Law is a leading law firm operating through a constituted and regulated legal entity that provide legal and other client services. Delta Law is the data controller responsible for your personal information processed via the Site.
COLLECTION OF YOUR INFORMATION
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. We may collect information about you in a variety of ways. The information we may collect on the Site includes:
Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us [when you register with the Site [or our mobile application,] or, when you choose to participate in various activities related to the Site [and our mobile application], such as online chat and message boards. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site [and our mobile application].
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. [If you are using our mobile application, this information may also include your device name and type, your operating system, your phone number, your country, your likes and replies to a post, and other interactions with the application and other users via server log files, as well as any other information you choose to provide.]
The Site [and our mobile application] may by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
Data From Social Networks
User information from social networking sites, such as [Facebook, Instagram, Twitter, LinkedIn], including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. [If you are using our mobile application, this information may also include the contact information of anyone you invite to use and/or join our mobile application.]
Mobile Device Data
Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device if you access the Site from a mobile device.
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.
Data From Contests, Giveaways, and Surveys
Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.
Mobile Application Information
If you connect using our mobile application:
- Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s [bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Data. We may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
- Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
GOALS FOR COLLECTING YOUR INFORMATION:
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
- with recruitment purposes, 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.
- 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 Delta Law.
- Relevant information as required by Know Your Client and/or Anti-Money Laundering 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 that 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 that may reveal information about your health or religious beliefs.
- Other information relevant to provision of Services.
Delta Law is primarily engaged by corporate entities and as such those instructors are not data subjects. However, as part of such instructions 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.
For instance, if we are providing pensions advice to trustees, we may be provided with and then process (amongst other information) details of benefit entitlement, pensionable service, pensionable salary, contact information, date of birth and gender in respect of members of pension schemes.
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 that 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 that 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.
- Additional information may be collected such as events you attend and if you provide it to us, dietary preferences that may indicate data about your health or religious beliefs.
If you are a potential recruit to join Delta Law:
- Name and job title.
- Contact information including email address.
- Curriculum vitae, including your age and/or gender if you provide it to us, your education, employment history and similar matters and similar information that you may provide to us.
- Other information relevant to potential recruitment to Delta Law.
USE OF YOUR INFORMATION
We may use your information for the following purposes:
- Fulfillment 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.
- What is 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 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 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.
- What is 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 regulatory 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.
- What is our legal basis?
Where we use your personal information in connection with a business transition, 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.
We use your personal information for the following recruitment purposes:
- To assess your suitability for any position for which you may apply at Delta Law 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 an in-person application.
- To review Delta Law’s equal opportunity profile in accordance with applicable legislation to ensure that Delta Law does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit.
- What is our legal basis?
Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for Delta Law. We will not process any special category data except where we are able to do so under applicable legislation or with your explicit consent.
- 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 (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.
- What is our legal basis?
It is in our legitimate interest to use your personal information for marketing purposes.
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 such as the Services you have viewed.
- 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 registered users like to see.
We also use this information for marketing purposes (see the marketing section above for further details).
- What is 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.
LEGAL BASIS FOR COLLECTION OF YOUR INFORMATION
It is necessary for us to use 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.
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
Interactions with Other Users
If you interact with other users of the Site [and our mobile application], those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.
When you post comments, contributions or other content to the Site [or our mobile applications], your posts may be viewed by all users and may be publicly distributed outside the Site [and our mobile application] in perpetuity.
We may share your information with our business partners to offer you certain products, services or promotions.
Social Media Contacts
If you connect to the Site [or our mobile application] through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.
Other Third Parties
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 draftsmen, court, opposing party and their lawyers, document review platforms and experts such as tax advisors or valuators.
- Third party service providers to assist us with client insight analytics, such as Google Analytics.
- 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.
Cookies and Web Beacons
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
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 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, or other third party experts including but without limitation Delta Law). 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.
- What is 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.
DURATION OF YOUR INFORMATION ON HOLD
For visitors to the Site, we will 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 the EU General Data Protection Regulation or similar 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 six years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation or similar 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.
CONFIDENTIALITY AND THE 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 unauthorized access, improper use or disclosure, unauthorized 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.
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
ACCESS OF 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 whom we’ve shared your personal information with 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 who we’ve shared your personal information with 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 who we’ve shared your personal information with 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 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.
- 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.
COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS
OUR COMMITMENT TO DATA SECURITY
To prevent unauthorized access, maintain data accuracy, and ensure the permitted use of information, the Delta Law uses commercially appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Unfortunately, the transmission of information via the Internet is not completely secure. However, we have put in place various security procedures as set out in this policy. Although we will do our best to protect your personal data. we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
OUR COMMITMENT TO CHILDREN’S PRIVACY
We do not seek to collect or maintain information on our website from those we know are under 18, and no part of our website is structured to attract anyone under 13.
- sending an email to: email@example.com; or
- calling us on: +977 (1) 424 3071
Last updated [May 02, 2020]