Privacy Policy

Privacy Policy

Overview

Travers Smith LLP ("Travers Smith"/"we"/"us"/"our") take privacy and our use of your data seriously and acknowledge the importance of protecting any personal information – that is, any information from which a person can be identified, such as names, contact details and ID information (in this policy we call this "Personal Information") that we hold.

This Privacy Policy sets out how we will use and protect any data (including Personal Information) collected by us when you visit our website, together with other Personal Information you may provide to us or which we acquire through our day-to-day business. We also have specific policies about:

  1. Personal Information which we hold about you for the purpose of and during your period of employment (whether as an employee or consultant) or period of membership as a partner, at Travers Smith (in which case please refer to our separate Staff Privacy Policy); and
  2. Personal Information which we hold in connection with and about job/vacation scheme/work experience applicants and prospective job/vacation scheme/work experience applicants (in which case please refer to our separate Recruitment Privacy Policy).

Together, these three policies make up the Travers Smith Privacy Policies.

We will, ordinarily, hold your Personal Information as a data controller. Whilst we aim, as a business, to give information about our privacy commitments directly to all the people whose data we hold, we do acquire some Personal Information in an indirect or incidental way (for example, we acquire Personal Information about our staff's family members when we ask our staff to provide emergency contact numbers).  Therefore, one of the purposes of this Privacy Policy (together with our other two privacy policies referred to above) is to provide privacy information to every person whose data we hold, including those with whom we do not have a direct relationship.

We will ensure that your Personal Information is handled in accordance with the law. The relevant law here is: (i) the United Kingdom General Data Protection Regulation; (ii) the Data Protection Act 2018; (iii) the EU General Data Protection Regulation 2016; (iv) the Privacy and Electronic Communications (EC Directive) Regulations 2003; (v) the French Data Protection Act (in respect of those website users who access our website for the purpose of conducting business with our Paris office, together with anyone else whose Personal Information we process as a result of dealings with our Paris office); and (vi) all similar or related legislation relating to the processing of Personal Information and/or privacy applicable to Travers Smith from time to time or as re-enacted, applied, amended, superseded, repealed or consolidated (together the "Data Protection Legislation").

USE OF YOUR PERSONAL INFORMATION

1.1 We may hold Personal Information because:

1.1.1 you supply it to us, for example, when you or your organisation seek legal advice from us, complete a form, make an enquiry, request to join our Alumni network, or otherwise interact on our website or other online platforms; 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 phone, email or other electronic means, or in writing; or when you enter into conversations with our lawyers, consultants and staff; or when you or your organisation offer to provide, or provide, services to us;

1.1.2 we learned it from someone else, either in the context of providing legal services to our clients, or in the context of our business more generally;

1.1.3 of the use of cookies (please see our Cookies Policy for further information) and tracking software which enables us to identify when legal updates, event invitations and other similar email communications (including embedded links within them) are opened; or

1.1.4 it is publicly available.

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

1.2.1 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. We use an automated third-party system to add your contact information to our contact database.

1.2.2 Financial and payment information

  • When instructing us, or if you or your organisation provide services to us, you may provide Personal Information including your bank account and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information.

1.2.3 Information about those related or otherwise connected to our staff

  • We sometimes ask members of our staff 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 staff.

1.2.4 Information about clients and those who work with clients or who are otherwise connected with the matters that we are asked to advise on

  • When we are instructed to provide advice, we will ask you for "know your client", anti-money laundering, and other necessary Personal Information which 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 don't have a direct relationship as is necessary in order for us to be able to provide our advice and services.

1.2.5 Information about individuals who are our suppliers or other business contacts (and individuals who are employed by our suppliers and business contacts)

  • If you provide services to us or have a business dealing with us (or are employed or engaged by an organisation which 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).

1.2.6 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 Policy for further information in this regard. We also collect information such as passwords, to enable you to access password-protected platforms or services.

1.2.7 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.

1.2.8 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:

1.3.1 provide our services;

1.3.2 run our business affairs, including internal record keeping;

1.3.3 carry out verification checks, for example in relation to anti-money laundering and know your client procedures;

1.3.4 comply with our legal obligations, including reporting obligations;

1.3.5 manage access to our premises and for security purposes;

1.3.6 protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;

1.3.7 send business or marketing communications (such as legal updates) which we think may be of interest (we will provide a simple mechanism for you to unsubscribe from such communications if you so wish);

1.3.8 organise and hold marketing events in connection with the promotion of our business; or

1.3.9 carry out our Corporate Social Responsibility Programme.

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 which 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. In some instances, we may use your Personal Information in order to enable us to perform a contract which we have in place with you.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

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.

HOW AND WHY WE SHARE YOUR PERSONAL INFORMATION, AND THIRD-PARTY WEBSITES

3.1 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 which 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 IT and HR-related products and services, including those hosted in the cloud. You acknowledge that such third parties may receive and process your Personal Information. We will never sell your Personal Information to third parties.

3.2 In addition, it may 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.

3.3 In processing your Personal Information, it will sometimes be necessary for us to transfer your Personal Information outside the UK or the European Economic Area ("EEA") (as applicable) to third parties such as overseas advisors or service providers. Your Personal Information may also be accessed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. This includes people engaged in, among other things, the provision of support services to us. In such circumstances, we will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and Data Protection Legislation. We may enter into contracts with entities based outside the UK or the EEA, where this is required by Data Protection Legislation.

3.4 This 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. As such, the operators of those websites are solely responsible for any personal data which they collect about you via their website, and such data will be collected in accordance with their own privacy policies.

YOUR RIGHTS AND DATA ACCURACY

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

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

4.2.1 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;

4.2.2 ask us to make any changes to ensure that any Personal Information we hold about you is accurate and up to date; and

4.2.3 in some cases, ask us to transfer any information we hold about you to a specified third party.

If you wish to exercise any of these rights, please contact us at one of the email addresses set out below.

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

CHANGES TO OUR PRIVACY POLICY

Travers Smith may amend this Policy at any time. Any changes to this Policy will be posted on our website at www.traverssmith.com. A version of this Policy in French is available here.

CONTACT US AND COMPLAINTS

Should you wish to exercise any of the rights set out above, or if you have any questions or concerns about the way in which we have handled your Personal Information, please send an email to privacy@traverssmith.com, marked for the attention of either the firm's Data Privacy Counsel or, where your query or concern relates to the activities of our Paris office, the Paris office's Head of Department.

Alternatively, you have the right to make a complaint to the Information Commissioner's Office (which is the supervisory body in the UK) or, if you are an EU data subject, one of the competent European supervisory authorities.

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