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MAILINGS PRIVACY POLICY

Clients rely and have relied for decades on the quality of Curtis’ legal advice as well as its high level of discretion and sensitivity in looking after its clients’ needs. 

We take the same care in our approach to our clients’ and contacts’ privacy.  This includes contact details and other data, which we use in order to send valuable insight, news alerts, legal updates and occasional event invitations (“Mailings”).

In order to send you news alerts, updates and to invite you to events, which we think you will find relevant and be happy to receive, we retain certain of your personal data within our systems.

In this Privacy Policy we set out what personal data we collect and process, the purpose for which we retain it and to whom your personal data may be disclosed by us in context of these Mailings. This document also includes a summary of your rights with respect to the processing of your personal data. Please read this Privacy Policy, which forms part of our broader Privacy Statement.

1. Whose personal data do we collect and process?

In the context of our Mailings, we collect and process your personal data because you are our client or other valued contact.

2. How do we collect and process your personal data and why?

We may collect information about you:

  • directly from you, such as the information you provided to us when you opted-in for our Mailings;
  • directly from you, such as via a business card that you have provided to one of our attorneys or via your attendance at one of our events;
  • from other sources, such as your (former) employer or colleagues;
  • from publicly available sources such as LinkedIn or the corporate website of the organization you are working for; and
  • by means of cookies (that are placed when you opt-in for our Mailings and in any of our Mailings). For more information on the cookies we use in this respect, please see below.

 

We have two legal bases for processing personal data with respect to our Mailings:

  • your active consent to receive such Mailings; or
  • our legitimate interest if you are our client or our professional contact.  This forms part of our objective to communicate relevant legal and tax developments to you and invite you and possibly your partners or spouses to events. We aim to send you only Mailings that are relevant to you or that we think are likely to be of interest or value to you. Furthermore, we use the information provided by you to better understand the recipients of our Mailings and to improve our Mailings and service offering.
     

3. What personal data do we collect and process about you and why?

 Personal data:

 Purposes:

 name*

 to correctly address our Mailings

 position or profession

 to correctly address you and to customize our  Mailings

 title(s)

 to correctly address you

 email address*

 to send you the Mailings

 telephone number, mobile telephone  number   or facsimile number

 to contact you

 gender

 to address you correctly

 company or organization

 to accurately reflect your organisation on a name badge and to provide the business   relationship context

 name of your partner

 to invite your partner to our events (if appropriate)

 link to your LinkedIn page

 to keep your personal data up-to-date

 your contact person at Curtis

 to correctly address you and to customize our Mailings

 Personal data related specifically to the Mailings we send or have sent to you

 marketing lists in which you are included   based on your areas of interest

 to customize our Mailings

 (previous) Mailings we have sent you

 to analyse and monitor the Mailings we send to you as an individual contact of the   firm

 opt-in/opt-out preferences

 to ensure that we do not send you Mailings you do not wish to receive

 whether you received, opened, forwarded or   deleted individual Mailings or clicked on   links embedded within it

 to analyse engagement with our Mailings, with a view to improving future Mailings


Without the personal data marked with an asterisk (*) we cannot send you any Mailings.

4. With whom do we share your personal data?

In the context of our marketing Mailings detailed in the above table, we may share your personal data with third parties such as event organizers or our online mailing tool supplier, with whom we have appropriate contractual safeguards to protect the security of your personal data and restrict its use in line with current data protection regulations. We may occasionally share your personal data with a local event provider in order to, e.g. produce name badges locally, in which case it shall be ensured that measures are taken to ensure adequate protection of your personal data in accordance with applicable data protection legislation.

We may also share your personal data with other Curtis offices. If a Curtis office within the European Economic Area (“EEA”) transfers your personal data to a Curtis office outside the EEA, the Curtis offices within the EEA shall ensure that the country to which the data is transferred is protected by:

  1. an adequacy decision by the European Commission, including EU-U.S. Privacy Shield; or
  2. adequate safeguards, with the implementation of model clauses and/or binding corporate rules.
     

5. How long do we store your personal data?

We will store your personal data as listed above until you inform us that you no longer wish to receive our Mailings, or unsubscribe via our mailing system, after which we will stop sending you Mailings.

Please note that we keep a record of all email addresses, which have been the subject of an Unsubscribe request.  This is to ensure that such email addresses are not added back into mailing lists without the data subject’s consent. 

If it appears that your email address is no longer current (e.g. we have received a “hard bounce” notification from our mailing system) we will cease to send to that email address.

6. What are your rights and how you can exercise them?

You can change your preferences through our Preference Manager at any time – and change your mind later.

If you unsubscribe either through our Preference Manager or by clicking unsubscribe at the bottom of every mailing, we will stop sending you Mailings. 

You have, or may have, one or more of the following rights under the General Data Protection Regulation (GDPR):

  • information about and access to your personal data;
  • rectification of your personal data;
  • erasure of your personal data (‘right to be forgotten’);
  • restriction of processing of your personal data;
  • object to the processing of your personal data;
  • receive your personal data in a structured, commonly used and machine readable format and to (have) transmit(ted) your personal data to another organization.

 

Finally, individuals to whom the GDPR applies have the right to lodge a complaint with the relevant Data Protection Authority, such as the Information Commissioner’s Office (ICO).

To exercise any of the above rights, please email privacy@curtis.com to obtain and complete a Request Form.

Please note that nothing in this Mailings Privacy Policy shall give you any right or rights, which you do not have under the GDPR.

7. Use of cookies in Mailings

Our Mailings make use of tracking cookies through our Mailing provider, Vuture, to track visitor statistics. We use these statistics to refine and improve our Mailings, the aim being to ensure the relevance of our Mailings.

If you opt in to our Mailings, downloading images or clicking on a link in any of these Mailings will cause you to be personally identified. This means we can see whether you open our Mailing. If you wish to avoid this tracking, you can unsubscribe from our Mailings or customise the settings of your browser so that it refuses cookies.

Most web browsers automatically accept cookies, but you can usually customize the settings of your browser so that it refuses cookies. You must set your settings for each browser and on each computer you use. Click on the name of your browser to read how to customize your settings:

Internet Explorer
Mozilla Firefox
Apple Safari
Google Chrome

8. How to get in contact about Privacy

If you have any questions, comments or complaints in relation to this Privacy Policy or the processing of your personal data by us in the context of the Mailings, do not hesitate to contact your usual Curtis contact or our Chief Privacy Officers of Curtis. 

Curtis’ Chief Privacy Officers are Jonathan Walsh and Winta Jarvis. You can contact them at privacy@curtis.com

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