Personal data refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (the “Personal Data”).
Responsibility of your Personal Data
lecocqassociate Group (as defined below) is responsible for your Personal Data. lecocqassociate Group consists of three (3) international offices: lecocqassociate Geneva, a boutique law firm; lecocqassociate Malta, a regulatory advisory practice and lecocqassociate Dubai, a structuring advisory practice (collectively, the “lecocqassociate Group” and individually, the “lecocqassociate Entity”).
Specifically, your data will be controlled by the lecocqassociate Entity that you have instructed or that is providing services or communication to you in your jurisdiction. However, please note that your Personal Data can be transferred within the lecocqassociate Group, for the provision of services to you.
Type of Personal Data being collected
The Personal Data that we collect about you may include:
Collection of your Personal Data
We may collect Personal Data about you in a number of circumstances, including:
In some circumstances, we collect Personal Data about you from a third party source. For example, we may collect Personal Data from your organisation, other organisations with whom you have dealings, government agencies, credit reporting agency, an information or service provider or from a publicly available record. In such cases, the purposes for the collection of your Personal Data from a third party source will still be the permitted purposes (as defined below) mentioned in this Privacy Notice.
The types of Personal Data which may be collected from third party sources include your name and surname, email address and other relevant contact details.
The requirement of providing us with your Personal Data and the consequences in the case you do not provide such
As a general principle, you will provide us with your Personal Data purely on a voluntary basis by way of explicitly providing your consent. Should you choose not to consent or to provide your Personal Data, then lecocqassociate Group may not be able provide you with the requested service and/or be able to take the necessary action.
By way of an example, as a result of not receiving your consent, we may not be able to:
In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant Personal Data. Moreover, in the course of our relationship, your decision not to provide us with ongoing personal information as might be required for anti-money laundering purposes, might lead to lecocqassociate Group having to terminate the relationship with you.
We will notify you accordingly of the purposes for which your Personal Data is being required and whether there will be any detrimental effects in the case that you do not provide such Personal Data.
Purpose of processing your Personal Data
We may use your Personal Data for the following purposes only (the “Permitted Purposes“):
Where you have expressly given us your consent, we may process your Personal Data also for the following purposes:
We will not use your Personal Data for taking any automated decisions affecting you or creating profiles other than described above.
Depending upon the specific Permitted Purposes we use your Personal Data, we may process your Personal Data on one or more of the following legal grounds:
In addition, the processing may be based on your consent where you have expressly given that to us (as described above).
Recipients of your Personal Data
We may share your Personal Data in the following circumstances:
Otherwise, we will only disclose your Personal Data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
International transfer of your Personal Data
lecocqassociate Group is a globally active boutique law firm . Hence, we may transfer your Personal Data outside of the European Union (the “EU”) and/or the European Economic Area (the “EEA”) if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the Swiss Federal Act on Data Protection as well as the General Data Protection Regulation (EU) 2016/679 (“GDPR”) or other relevant laws (as applicable). This includes entering into the EU Standard Contractual Clauses which are available here (if applicable).
All our offices throughout the world will at all times ensure a level of data protection at least as protective as that required in the Switzerland and EEA (as applicable). We will also require our agents, consultants and sub-contractors and others who are outside the EEA and Switzerland (as applicable) and to whom we transfer your personal data to ensure a similar level of data protection.
When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data. Such transfer occurring to countries outside of the EEA is only carried out if the EU has approved such third countries as having equivalent data protection laws in place.
You may contact us anytime using the contact details further below if you would like further information on the above.
Personal Data about third parties which you provide to us.
Security measures for the safekeeping of your Personal Data
We will take appropriate technical and organisational measures to keep your Personal Data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Data. Personal Data may be kept on our personal data technology systems, those of our service providers or in paper files.
Updating your Personal Data
If any of the Personal Data that you have provided to us changes, or if you wish to cancel any request you have made to us, or if you become aware that we have any inaccurate personal data about you, please let us know by contacting us using the contact details mentioned hereunder.
We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.
We will, in particular, retain your Personal Data where required for lecocqassociate Group to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.
Your Personal Data will be deleted in the following circumstances:
If you wish to do any of the above please use the contact details provided below.
We may request proof of identification to verify your request. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your Personal Data, and for any additional copies of the Personal Data you request from us.
We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one (1) month after of receipt of your request. In exceptional cases, we may extend this period by two (2) months and we will tell you why.
If you are not satisfied with our response, you may take your complaint to the relevant data protection regulator.
If you would like to contact us with any queries or comments, please contact our Chief Operating Officer by using the below contact details:
Swiss Urban Factory
The Regulatory Suite
5 St. Frederick Street Valletta
Malta VLT 1470
Email address: firstname.lastname@example.org
Contact Number: +35622482910
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