For the purposes of this statement, “Data Protection Legislation” means all applicable legislation relating to privacy or data protection in force from time to time including any statute or statutory provision which amends, extends, implements, consolidates or replaces the same, including without limitation, the EU General Data Protection Regulation 2016/679 (“GDPR“), and the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore, and a “controller” or “processor” shall have the same or equivalent meaning as given to it under applicable Data Protection Legislation.
Who do we collect information on?
This privacy notice applies to the following individuals whom we collect personal information from or about:
- those who have engaged with us in relation to expressing interest in attending or supporting one of our events (together clients);
- third parties with whom we interact as part of providing our services to our clients (intermediaries);
- those who are, work for or are agents of, suppliers or service providers who provide goods and services to us;
- those who request newsletters, marketing material or other publications from us; and
- visitors to our website or LinkedIn page or events.
What is personal information?
Personal information means any information about you from which you can be identified. This includes but is not limited to, name, address, date of birth, gender and national identity or passport numbers. There are “special categories” of more sensitive personal information which may only be collected for specific reasons and/or require a higher level of protection under applicable Data Protection Legislation (e.g. where it is necessary to accurately establish or verify an individual’s identity to a high degree of fidelity). These include information regarding race, health, genetic information and biometric data, religious beliefs, sexual orientation, criminal convictions, political opinions.
How we collect and use personal information about you
We collect personal information either directly from you when you engage with us or through third party intermediaries who may suggest you have an interest in our events.
By using our website or otherwise contacting us, obtaining services from us or by providing your personal information to us via the forms or contact options on this website you acknowledge that you have read and understood this privacy statement.
General visitors to the website
No personal information is collected about general visitors to our website. However, in addition to the information collected by us in accordance with this privacy statement, your browser supplies some basic information about your visit. The collection of this information is common practice and is used to analyse and understand how the website is being used. The following information is logged:
- technical information, including the internet protocol (“IP“) address (the internet address of your computer) used to connect your computer to the internet, your login information, the type of computer you are using, the type and version of the browser, operating system and platform you are using, time zone setting, browser plug-in types and version;
- information about your visit (e.g. date and time of your visit), including the uniform resource locators (URLs) of websites that referred you to the website and the path you take through the website, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page, and any phone number used to connect with us; and
- location data – we collect information through our website as to your real time location to provide location services, where requested or agreed to by you, in order to allow check-in, or to deliver content or advertising that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to our website.
Delivery of location services will involve reference to one or more of the following:
- The coordinates (latitude/longitude) of your location.
- Look-up of your country of location by reference to your IP address against public sources; and/or your identifier for advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.
Personal information provided via the website
In certain areas of our website, you can choose to provide personal information by completing any of the forms or using any of the email addresses which are included on this site or on LinkedIn.
The personal information we hold
We collect a variety of personal information from you and about you. The extent of the personal information collected will depend on a variety of factors including the nature of the relationship between us and the extent of the contact with you.
The types of personal information we may process are set out below:
- your contact details including (but not limited to) your full name, postal address, email or other electronic communication addresses and telephone numbers. In certain circumstances we may also record your job title and other identification information to the extent permitted under application Data Protection Legislation as set out below. Please note that, in some jurisdictions, your business contact information is not treated as personal information in accordance with applicable Data Protection Legislation (unless such information is provided by you solely for your personal purposes), and therefore your rights in relation to such information may be different to those set out in this statement
- KYC information and documentation which may be required to fulfil legal and regulatory requirements. This may include, but is not limited to, identity information such as your passport or other identity document details, date of birth, nationality, place of birth and country of residence, job title, source of wealth or funds and other information concerning your background (which may include sensitive information such as criminal records) and for certain types of personal information, only where this is necessary to enable us to carry out appropriate checks in relation to contracts with you or someone else that you work for or are otherwise related to, or to accurately establish or verify your identity to a high degree of fidelity and to the extent permitted under application Data Protection Legislation
- biometric data including a photographic likeness of you for identification and verification purposes
- personal information provided in the course of the provision of legal and corporate services, for example, information on professional relationships and background, your business dealings with us or any of our clients which we manage or administer, financial wealth and assets held, transactions entered into, legal advice given (and any actions taken as a result of such advice) tax status, disputes and court proceedings engaged in which may also include sensitive information such as marital status, mental and physical health and criminal allegations or convictions
- financial information such as payment related information
- professional interests and preferences with respect to marketing interactions, attendance at conferences, events or seminars; and
- any other personal information which you may provide to us.
How and why do we use personal information?
For each of the purposes for which we process information, we rely on one or more of the following legal justifications:
- Contractual necessity. Personal information is processed in order for us to discharge any contractual relationship.
- Legitimate interest and/or business improvement. Personal information is processed in circumstances which can balance our legitimate interests with your own legitimate interests and in accordance with applicable Data Protection Legislation. We consider our legitimate interests to include: (a) providing legal and corporate services; (b) carrying out such services effectively and efficiently; and (c) communicating with you in respect of those aspects of our services which we consider to be of relevance to you.
- Legal and regulatory requirement. Personal information is processed in order for us to comply with a legal obligation (other than one imposed by a contract).
- Consent. Personal information is processed on the basis of consent given by you (where legally required). We will only seek to rely upon your consent where no other legal justification is available to us.
- Legal proceedings, etc. Personal information is processed on the basis that it is necessary for (a) any legal proceedings; (b) obtaining legal advice; or (c) establishing, exercising or defending legal rights, and in accordance with applicable Data Protection Legislation.
- Explicit Consent. Biometric data where used for identification purposes, is considered as special category personal data and accordingly is subject to additional controls and protections. We therefore obtain your explicit consent in order to process such data for the purposes of verifying your identity in order to comply with anti-money laundering, compliance screening and to prevent fraud and other crimes.
We process personal information for the following purposes.
Purpose: provision of services and developing those services, including:
- delivering our services to our clients, developing those services and managing, maintaining and developing our relationships with our clients
- performing the service which we have been engaged to provide
- facilitating effective client and matter management including collation of know-how materials, and generating internal financial and marketing reports; facilitate administrative or operational processes within our business, for example assessing legal and financial risks to our business and debt management including credit control and collecting debt
- engaging other service providers to provide services to you where necessary to facilitate the provisions of services to you in connection with the engagement
- improving and developing our products and services including carrying out analysis on our performance to ensure that our care is of the highest standard
- respond to requests, enquiries or complaints received; and
- providing access to any of our services
In the performance, delivery and development of our services we may use generative artificial intelligence (GenAI) with the legitimate interests of improving the efficiency and effectiveness of our services.
Legal justification: contractual necessity and legitimate interests.
Purpose: legal and regulatory requirements.
- responding to requests, enquiries or complaints received; and
- accurately establishing or verifying your identity to a high degree of fidelity as part of our checks in relation to anti-money laundering, compliance screening and to prevent fraud and other crimes.
Legal justification: legal and regulatory requirements and explicit consent in relation to biometric data solely.
Purpose: marketing.
To promote our services and provide newsletters, marketing material or other publications to our contacts and to invite you to conferences, events or seminars which may be of interest to you to the extent permitted under applicable Data Protection Legislation. This may involve contacting you or, where applicable, individuals within your organisation using the contact details that you have provided to us
- to manage our circulation lists for such marketing material and events; and
- to compile anonymous statistics, for example, website usage statistics.
Legal justification: consent, legitimate interests and/or business improvement (to the extent permitted under applicable Data Protection Legislation).
Individuals have the right to unsubscribe from mailings or manage their preferences at any time by emailing Jeremy.Snead@ogier.com