We will always comply with the General Data Protection Regulation (GDPR) and the Act No.101/2000 Coll. On the Protection of Personal Data and on Amendments to Some Acts, as amended, when dealing with your personal data. Further details on the GDPR can be found at the website for the Office for Personal Data Protection. For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
1. Purpose of this Policy
2. Who we are and what we do
Strategic Business Solutions Boutique/SBSB is an international legal practice group providing client services worldwide through the following separately constituted and regulated legal entities which provide legal and other client services in accordance with the relevant laws of the jurisdictions in which they respectively operate:
- SBSB InterFin OU, Harju maakond, Tallinn, Estonia, Kesklinna linnaosa, Tuukri tn 19-tuba 315, 10152, tel.: +372 610-42-06
The terms “SBSB”, “we”/”us”/”our” mean one or more of the above legal entities. Any reference to SBSB “location” means any office, associate office, facility, associate firm, or entity with a special alliance with our international legal practice.
Personal data is collected by each of the above legal entities. Our primary data controller in the EU is SBSB s.r.o., which also acts as EU representative of the group for data protection issues.
3. What personal information we collect
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.
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
- 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:
- Your full name.
- Contact information including the company you work for, email address telephone number where appropriate.
- The country you are in.
- 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, telephone number 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 SBSB.
- 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 which 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 which may reveal information about your health or religious beliefs.
- Other information relevant to provision of Services.
SBSB 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.
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 which 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 which 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 which may indicate data about your health or religious beliefs.
If you are a potential recruit to join SBSB:
- Name and job title.
- Contact information including email address.
- Curriculum vitae, including your age, gender, your education, employment history and similar matters and similar information that you may provide to us.
- Other information relevant to potential recruitment to SBSB.
4. How we use your personal information
We may use your information for the following purposes:
Fulfilment 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 agreement(s) with you apply when we provide the Services.
Our legal basis:
It is necessary for us to process your information to perform our obligations in accordance with any agreement 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.
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.
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 may 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 Combating Terrorism Financing Rules, conflicts or similar obligations);
- to enforce our legal rights;
- to protect the rights of third parties.
Our legal basis:
Where we use your personal information 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 may use your personal information for the following recruitment purposes:
- to assess your suitability for any position for which you may apply at SBSB whether such application has been received by us online, via email or by hard copy or an in-person application.
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 SBSB. We will not process any special category data except where we are able to do so under applicable legislation or with your explicit consent.
We carry out e-mail marketing activities using your personal information. 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 Analysis section below for more details of the information collected and how it is collected) to send you marketing communications.
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.
This includes the following:
- 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.
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).
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 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.
5. Collection of information by third-party sites and sponsors
The Site may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as SBSB has no control over information that is submitted to, or collected by, these third parties.
6. Disclosures of your personal information
SBSB is an international law firm and any information that we collect or that you provide to us may be shared and processed by any SBSB entity listed above. 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.
- Regulators/tax authorities/corporate registries.
- Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, IT support service or software providers, document and information storage providers.
- Third parties engaged in the course of the services we provide to clients such as counsel, clerks, notaries, and experts.
- 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 documents to you.
- 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 effectively.
As mentioned above, we may appoint sub-contractor data processors as required to deliver the Services, 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, lawyers, accountants, registered agents, banks or other third parties. 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.
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.
7. International transfers of your data
In order to provide the Services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it.
All SBSB entities have signed a data sharing agreement which is based on the EU standard contractual clauses to ensure we will comply with our legal and regulatory obligations in relation to personal information, including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.
8. Retention of your personal information
We will retain your personal information for as long as we are in agreement and/or communication with you and for as long afterwards as it is in our legitimate interest to do so or for as long as it is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment, exercise or defense of legal claims. We securely destroy all financial information once we have used it and no longer need it.
9. Confidentiality and 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 unauthorised access, improper use or disclosure, unauthorised 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.
10. Your rights
You have the following rights in relation to the personal information we hold about you:
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.
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 who we’ve shared your personal information with so that you can contact them directly.
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.
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.
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.
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.
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.
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 (for details, please see Complaints section 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.
If you have a problem or complaint about how we process your personal data, please let us know. We will respond to a complaint as soon as possible, but within 10 working days to let you know who is responsible for managing your complaint. We will also try to resolve the complaint within 10 working days. When this is not possible, we will contact you within that time to let you know how long it will take to resolve the complaint. If you believe that we have not adequately dealt with your complaint, you may lodge a complaint with our Supervisory Authority:
The Data Protection Inspectorate
10129 Tallinn, Estonia
+371 627 41 44
or refer to your local privacy authority.