Privacy Notice

1.1 We may hold Personal Information because:

• you supply it to us, for example, when you seek legal advice from us, complete a form, make an enquiry, request to join our Alumni network, or otherwise interact with us or our website; or when you attend our seminars or other events or sign up to receive information from us, including training; or when you correspond with us by telephone, email or other electronic means, or in writing; or when you enter into conversations with our lawyers, consultants and other personnel; or when you offer to provide, or provide, services to us;
• we learnt it from someone else, either in the context of providing legal services to our clients, or in the context of our business more generally;
• of the use of cookies (please see the Cookies Notice on our website for further information) and tracking software that enables us to identify when legal updates, event invitations and other similar email communications (including embedded links within them) are opened; or
• it is publicly available.

1.2 We may collect (and use for the purpose for which it was collected, as outlined in this Privacy Notice) the following information about you:

• Identity and contact information: When contacting or visiting us, whether online, via telephone, via email, in writing, or otherwise, or when instructing us, you may provide Personal Information about yourself, including your name, address, telephone number, date of birth, passport number, job title and function, photographs and other personal data concerning your preferences relevant to our services. When you email us, we use an automated third-party system to add your contact information to our contact database. We also use a third-party software system to cleanse the data in our client relationship management system.
• Financial and payment information: When instructing us, or if you provide services to us, you may provide Personal Information including your bank account details and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information.
• Information about those related or otherwise connected to our personnel: We sometimes ask our personnel to provide details of their next of kin for the purpose of our emergency scenario planning or in case an incident occurs at work. We may also ask for details of their dependents, spouses and/or other people in relation to their employee benefits arrangements, so that we can use this information for the benefit of our personnel.
• Information about clients and individuals who are connected with client matters: When we are instructed to provide advice, we will ask you for "know your client", anti-money laundering, and other necessary Personal Information that the law requires us to collect. We will only use "know your client" information for the purpose of verifying identity in connection with matters that we are asked to advise on and as otherwise prescribed by law. We may also collect Personal Information about you and other third parties with whom we may not have a direct relationship as is necessary in order for us to be able to provide our advice and services.
• Information about individuals who are (or who are employed by) our suppliers or other business contacts: If you provide services to us or have a business dealing with us (or are employed or engaged by an organisation that provides services to us or has a business dealing with us), we may acquire your name, contact details, some employment information and copies of ID documents or similar information (if, for example, you are a director at a business in respect of which we are required to conduct due diligence).
• Profile and usage information: We collect Personal Information about your preferences in receiving marketing information from us, your communication preferences, and information about how you use our website. Please see our Cookies Notice for further information in this regard. We also collect information such as passwords, to enable you to access password-protected platforms or services.
• Physical access information and dietary requirements information: We may collect Personal Information such as access times and requirements and dietary requirements or preferences when you visit our premises.
• Other special category data: We may be instructed to advise on, or as a result of our corporate social responsibility and pro bono work get involved with, matters that require us to collect and use sensitive (otherwise known as special category) Personal Information relating to you or a third party (that is, information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life or sexual orientation, or genetic or biometric data). For the same reason, we may also have to collect and use information about criminal offences or alleged criminal offences committed by you or by a third party.

1.3 We may use your Personal Information to:

• provide our services;
• run our business affairs and maintain internal records;
• carry out verification checks, for example in relation to anti-money laundering and know your client procedures;
• comply with our legal obligations, including reporting obligations;
• manage access to our premises and for security purposes;
• protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
• send business or marketing communications (such as legal updates) that we think may be of interest (we will provide a simple mechanism for you to unsubscribe from such communications if you so wish);
• organise and hold marketing events in connection with the promotion of our business;
• carry out our Corporate Social Responsibility Programme; or
• respond to requests, queries or complaints from you.

1.4 The legal basis on which we hold your Personal Information is primarily for the purpose of pursuing our legitimate interests as a business that provides legal advice and services. In some instances, we may rely on your express consent to use your Personal Information, but we will let you know (and give you the chance to withdraw consent) if we do. We may also use your Personal Information to enable us to perform a contract that we have in place with you; as necessary to comply with our legal obligations; and/or (in respect of your special category Personal Information) for the purpose of establishing, exercising or defending legal claims.

We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation and our own internal rules and policies allow.

3.1 If you are a visitor to our London office we will, for security purposes, share your name and the name of the organisation for which you work with the building reception team employed by our landlord.

3.2 More generally, where it is necessary for the performance of our contract with you (or the organisation you represent) or for our internal business processes, we may share your Personal Information with certain third parties who reasonably need it in order to perform a function for you or the business that you represent, or to provide a service to us – such as other advisers on a matter, other parties to transactions or disputes, or, in the case of suppliers to Travers Smith, providers of technology products and systems, including those hosted in the cloud. Subject to any other arrangement we may have in place with you, we may process your Personal Information using artificial intelligence tools, both in the general conduct of our business and in our provision of legal services. We only use such tools on Enterprise terms and with appropriate restrictions in place. We will never sell your Personal Information to third parties.

3.3 In processing your Personal Information, it will sometimes be necessary for us to transfer it outside the UK or the European Economic Area ("EEA") (as applicable). For example, we use the services of a document production team based in Manila, with the data shared with this team remaining on our servers at all times. Our service providers are bound by appropriate confidentiality obligations and transfers of data to them are made in accordance with the requirements of Data Protection Legislation. Your Personal Information may also be accessed on an occasional basis by our personnel when operating outside the UK or the EEA. We take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Notice.

3.4 It may also be necessary to disclose your Personal Information if we are under a duty to do so in order to comply with any legal obligation (such as anti-money laundering or tax disclosure obligations); carry out an internal investigation; enforce any agreement we have with you or with a related party; or protect the rights, property, or safety of Travers Smith and/or our clients, partners, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud and crime prevention and protection.

Our website includes links to third-party websites, such as LinkedIn and Twitter. Please note that when you click on a link to such a website, you will be leaving our website and accessing that other website. The operators of those websites are solely responsible for any Personal Information that they collect about you via their website, and such information will be collected in accordance with their own privacy policies.

5.1 You have certain rights in relation to your Personal Information. For example, you have the right to request that we erase your Personal Information (or part thereof) at any time, and we will comply with such request unless we have a lawful reason to retain your information (for example, to comply with our legal obligations).

5.2  You also have the right, subject to certain exemptions, to:

• see the Personal Information we hold about you (unless, for example, our duty of confidentiality to a client or other third party takes precedence over this right), and withdraw any consent you may have given to us to hold and use that Personal Information;
• ask us to make any changes to ensure that any Personal Information we hold about you is accurate and up to date; and
• in some cases, ask us to transfer any information we hold about you to a specified third party.

5.3 If you wish to exercise any of the above rights, please contact us using the details provided in Section 7 of this Notice.

5.4 Please ensure that any Personal Information you provide us with is accurate and complete and that you notify us of any changes to your Personal Information as soon as possible so that we can update our records.

6.1 Travers Smith may amend this Notice at any time. Any changes to this Notice will be posted on our website at www.traverssmith.com.

6.2 A version of this Notice in French is available here and a version in Dutch is available here.

7.1 Should you wish to exercise any of the rights set out above, or if you have any questions, complaints or concerns about the way in which we use Personal Information, please email the firm's Data Privacy Counsel at privacy@traverssmith.com. If you are based in the EEA or where your query, complaint or concern relates to the activities of our Brussels office, you may alternatively contact a representative of that office.

7.3 Our office contact details are available on the Contact Travers Smith page on our website. You can also submit questions or raise complaints or concerns using the online form on that page.

7.3 In addition, you have the right to make a complaint to the Information Commissioner's Office, which is the supervisory authority for data protection issues in the UK (www.ico.org.uk) or, if you based outside the UK, the relevant supervisory authority in your jurisdiction. For a list of the competent European supervisory authorities, see: https://edpb.europa.eu/about-edpb/board/members_en.