Privacy notice

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Privacy notice

Privacy notice

Ince & Co. is committed to protecting the privacy of your personal data in accordance with applicable Data Protection legislation.

Who we are

Axiom Ince Limited trading as Ince & Co. and its affiliated entities practice law internationally as “Ince & Co” or ‘Ince’.

References in this Privacy Notice to “Ince & Co.”, “we”, “our” or “us” means Axiom Ince Limited trading as Ince & Co., our affiliates, and the other partnerships and other entities or practices authorised to use the name “Ince & Co.” or describe themselves as being in association with Ince & Co. as the context may require.

Ince & Co. controls the collection and processing of any personal data that you provide in relation to this website. Where services are provided to you by any other Ince affiliate, the entity providing the service will be the controller of your personal data. This Privacy Notice applies to all such entities and/or affiliates.

The entity responsible for providing services to you will be stated in our Engagement Letter and it is this entity that will be the controller of your data. You can find more information about our local entities on our website under the ‘Legal Notices’ and ‘Contact Us’ sections. 

This notice applies whether you are, or you are acting on behalf of, a client or potential client of Ince & Co., or you are a professional, business contact, third party contact or job applicant of Ince & Co.

Personal Data we collect about you

Website enquires

You do not need to provide us with personal data to browse our website but if you decide to sign up for any of our mailings, or send an email for further information on our services, you will need to provide us with personal data in order to action your request. We may collect data relating to:

Data we may collect

Identification information such as title, name, the company you work for, your job title and your position;
Contact information such as telephone numbers, postal addresses and email addresses;
Financial information, for example, if you are using our online portal to pay for services;
Technical information such as IP addresses, details of the pages on our website you visit and online registration details; and
Health information, for example, if you are signing up for an event and have dietary requirements.

Storage

Information collected directly from you when signing up for newsletters or other online services will be stored in our Customer Relationship Management system.

Use

To complete any request for marketing or other services or to update your marketing preferences;
To promote our services and to contact you with information that we feel may be relevant including legal updates, newsletters and event invitations;
To improve our website user experience;
To facilitate our internal business operations; and
Monitoring and analysing our relationship with website visitors and other contacts to help us run and grow our business.

We have a Cookie Policy which is available separately from this Privacy Notice.

Providing legal and other services to our clients

In order to provide our services to you we will need to process your personal data. The types of data that we will process will vary depending on the instructions received but may include:

Data we may collect

Identification information such as title, name, address data of birth, gender, company information, health data, financial data or any other types of data relevant to us providing you with our services;
Contact information such as postal address, email address and telephone numbers; and
Employment information such as job title and employer.

Storage

Client information is contained on our secure email servers, our document management system, practice management systems and customer relationship systems. We may also keep paper files/records.

Use

To open a new client/matter file, conduct conflict checks and comply with applicable laws and regulations.
To communicate with you in regards to our retainer in order to fulfil our instructions and to provide legal or other services and otherwise complete our contract with you. Provision of services may include the conduct of litigation, transactional services or other legal services required;
To respond to any complaints or claims and to ensure that our business has access to the information required to consider such claims;
To develop our business and to profile our clients for the continued growth and success of our business;
To provide you with legal updates, event invites or other information we feel would be valuable to you or your business;
To market additional services that we may be able to provide;
To update our own records for audit and insurance purposes; and
To otherwise enable us to operate our business effectively.

Third parties involved in client matters

As a professional legal services business we will process data on third parties. This could be opponents in a litigation or contentious matter or the other side of a transactional arrangement. This could also include personal data on an opponent’s lawyers.

Data we may collect

Identification information such as title, name, the company you work for, your job title and position;
Contact information such as telephone numbers, postal addresses and email addresses;
Financial information, for example, if you are using our online portal to pay for services; and
Other information received is relevant to enable the provision of legal and other services to our clients. This will vary depending on the type of matter but may include insurer information, witness statements, correspondence, court documents and transaction documents. It may also include special category data.

Storage

Third-party information is contained on our secure email servers, our document management system and our practice management systems. We may also keep paper files/records.

Use

To communicate with third parties in relation to the provision of legal services to our clients;
To gather and investigate information relevant to our client(s) position to enable us to advise and act in the best interests of our client(s);
To make or receive payments on our client's behalf;
To update our own records for audit and insurance purposes;
To otherwise enable us to operate our business effectively such as the need to keep a record for conflict checking purposes;
To comply with our legal and regulatory duties or obligations. For example our obligations under the Money Laundering Regulations or to comply with our duty to the court;
To enable us to instruct third-party advisors to assist with our client's matters; and
To otherwise enable us to operate our business effectively.

Professional and business contacts

We may process the personal data of individuals that are not our clients but with whom we would like to develop our business relationship.

Data we may collect

Identification information such as title, name, the company you work for, your job title and position;
Contact information such as telephone numbers, postal addresses and email addresses;
Employment information such as job title and employer;
Other information received is relevant to enable the provision of legal and other services to our clients.

Storage

Professional and business contact information is contained on our secure email servers, our document management system, practice management systems and/or our customer relationship system. We may also keep paper files/records.

Use

To develop our business and to profile our contacts and business relationships for the continued growth and success of our business;
To provide legal updates, event invites or other information we feel would be valuable to our professional and business contacts;
To market services that we may be able to provide which would be of interest to our professional and business contacts;
To update our own records for audit and insurance purposes; and
To otherwise enable us to operate our business effectively.

Suppliers & service providers

We instruct third parties from time to time to assist us in providing our legal and/or other services. Examples could include barristers, foreign law and other experts, translators and other service providers. We also use suppliers to assist with the operations and management of our business such as outsourced services. For example IT, cleaning, facilities, banking, insurance and recruitment agencies.

Data we may collect

Identification information such as title, name, the company you work for, your job title and position;
Contact information such as telephone numbers, postal addresses and email addresses;
Employment information such as job title and employer; and
Other information received which is relevant to enable the provision of legal and other services to our clients or to provide services to our own business.

Storage

Supplier and service provider information is contained on our secure email servers, our document management system, practice management systems and/or our customer relationship system. We may also keep paper files/records.

Use

To develop our business and to assess the suitability of such suppliers and to enable them to pitch for or provide services to our business;
>To update our own records for audit and insurance purposes; and
To otherwise enable us to operate our business effectively.

Job applicants

Data we may collect

Identification information such as title, name, the company you work for, your job title and position and/or previous employment history;
Contact information such as telephone numbers, postal addresses and email addresses;
Employment information such as job title and employer;
Special category data to assist with our diversity and equality management (voluntary and by explicit consent only).

Storage

Supplier and service provider information is contained on our secure email servers, our document management system, practice management systems and specialist HR systems. We may also keep paper files/records.

Use

To enable the Firm to recruit new employees;
To run recruitment fairs;
To maintain accurate and up-to-date records;
To respond to and defend legal claims;
To promote equality in the workplace;
To otherwise enable us to operate our business effectively.

Visitors to our offices

We regularly receive visitors to our offices and may process personal data to ensure our premises remain secure, safe and to enable our business to operate effectively. Some of our locations are based in offices with other tenants and data may be passed to other operators managing the front house reception areas.

Data we may collect

Identification information such as title, name, the company you work for, your job title and position and/or previous employment history;
Contact information such as telephone numbers, postal addresses and email addresses; and
Employment information such as job title and employer.

Storage

Supplier and service provider information is contained on our secure email servers, our document management system and our practice management systems. We may also keep paper files/records.

Use

To ensure our buildings are secure and to provide a safe environment for all employees and guests;
To ensure compliance with Health and Safety procedures;
To confirm attendance at meetings or internal events;
To provide suitable refreshments; and
To comply with insurance requirements.

How and why we use your personal data

Whether we receive your personal data directly from you or from a third party, we will only use your personal data if we have a lawful reason for doing so. Such reasons will include:

Complying with our legal and regulatory obligations;
For the performance of our contract with you or to take necessary steps, at your request, before entering into a contract;
For our legitimate interests or those of any third parties;
When we have your consent to do so.

We may use your personal data to enable us to:

Provide legal advice or other services to you or one of our clients;
To manage our business relationships with you or your organisation;
Acting in compliance with our legal obligations, including with respect to anti-money laundering, sanctions check, conflict checking, financial/credit checks and any other means required to ensure compliance with law and regulation including compliance with the rules of the SRA or other local bar in another jurisdiction;
Gathering and providing information required by audits, enquiries or investigations by regulatory authorities or for insurance purposes or to consider and defend claims against our business;
Managing and securing access to our offices, systems and online platforms;
Monitoring our technology tools, including our websites and email communications;
Complying with court orders;
Processing that is necessary for the legitimate interest of our business or third parties provided that such interests are not overridden by your interests or fundamental rights and freedoms;
Keeping our databases up to date with relevant and accurate information;
Communicating with you about events and seminars or sending briefings or other marketing materials we feel will be of interest to you, your organisation or business.

Marketing

We may use your personal data to send you marketing communication by email, text, telephone or post on legal developments that may be of interest to you and/or information about our services. We have a legitimate interest in processing your personal data in this way. This means we do not always need your consent to send you marketing communications. However, where consent is required, we will ask for this separately and clearly. You have the right to opt out of marketing communications. An unsubscribe link will be included in all marketing communications. We may, from time to time, ask you to update your marketing preferences to ensure you receive communications that are relevant to you or to take into account changes in law or regulation.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost or used or accessed unlawfully. However, the transmission of data via the internet is not completely secure and although we use a number of technical and organisational measures to protect your data, we cannot guarantee the security of your information transmitted online.

We have procedures in place to deal with any suspected data breach and will notify you, and any applicable regulator(s), of a suspected data breach when legally required to do so.

Sharing Personal Data

We will not use your data for any other purpose than set out above, or disclose it to any third party, without your consent unless we are required to do so by law or as mentioned in this section.

Other professionals and other bodies

In order to provide some of our professional services, we may use the input of third parties such as counsel or other external lawyers, accountants and experts, or we may refer you to such third parties, with your consent or where this is necessary for the performance of our contract with you (or the company or other person you represent). This will require the disclosure to such third parties of your contact details, as well as further personal data about you which is relevant to the services they provide. We may also be required to disclose your personal data to regulators, by order of the court, Government departments and local authorities and similar bodies in order to comply with legal obligations or to perform our contract with you (or the company or other person you represent).

External audits

External organisations may conduct audits or quality checks for us, either where this is necessary for compliance with our legal obligations or for the legitimate interests we have in improving our business and services. These external organisations are required to maintain confidentiality in relation to your files. If you do not want your file to be part of this process, please tell us as soon as possible.

Data processing services

Some of our data processing services are supplied by third-party providers, who will need to have access to your data for that purpose. Such third-party suppliers will be appointed on the basis that they provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing will meet the requirements of the applicable Data Protection legislation and ensure the protection of the rights of the data subjects, and will carry out processing only on our written instructions, or where we have a legitimate interest in doing so, as indicated above.

Transferring our rights and duties

We may transfer your personal data to anyone to whom we may transfer our rights and duties under the terms of our retainer with you (for instance, if you wish to change your professional representation, or where we do so for the purposes of a business re-organisation and administration or if our business is merged with or we are acquired by a third party). We will do this in order to perform our contract with you (or the company or other person you represent) or where this is necessary for the legitimate interests we have in improving our business and services.

Compliance with legal obligations

We may disclose your personal data if we are required to do so in order to comply with any legal or regulatory obligation or request, or where we have a legitimate interest in doing so, such as in order to enforce or apply our contract with you, to investigate potential breaches, or to protect our property and rights or those of others. This may include exchanging information with other companies and agencies for the purposes of credit risk reduction and complying with legislation concerning money laundering, tax evasion, crime prevention and fraud protection.

Transfers outside the UK and EEA

In order to provide some of our professional services, we may share your personal data with one or more third-party providers situated in countries outside the United Kingdom and/or the European Economic Area (including the USA) that do not have the same standards of Data Protection laws. We may do so with your consent, or where it is necessary for the performance of the contract we have with you or for the establishment, exercise or defence of legal claims. However, we will ensure that contractual or other safeguards are in place to ensure that your personal data is adequately protected and that enforceable rights and effective legal remedies are available for data subjects, and will inform you of the nature of these safeguards at the relevant time.

Professional or business contacts

If you are not a client (or a representative of a client) but have provided us with your professional or business contact details or other relevant personal data, we may share your personal data with our other professional or business contacts, on the basis that it is necessary for our legitimate interests in promoting and marketing our professional services, unless you indicate otherwise.

How long do we keep personal data?

If you contact us with an enquiry about our professional services but you do not subsequently become a client (or the company or other person you represent does not do so), it is our policy to delete your personal data after twelve months.

If you are or become a client (or the company or other person you represent is or becomes a client), we normally retain contract information (including personal data) for a minimum period after the end of the relevant contract or client relationship, or for longer where it is necessary for us to do so for compliance with regulatory or other legal obligations, or for the establishment, exercise or defence of legal claims, or where we agree with you to do so. In some cases, it may be necessary for us to retain records indefinitely.

Our full data retention policy is available on request.

Personal data relating to our professional contacts will be retained for as long as necessary, or until you indicate otherwise to us, but we will aim to update our contacts’ preferences on a periodic basis.

In certain cases, it may not be physically possible to delete certain data (for instance, where it is stored on a secure external server), in which case we will take appropriate steps to ensure that it is not available for re-use or disclosure to third parties.

Your rights as a data subject

As a data subject, you have certain legal rights (subject to certain exceptions under the Data Protection legislation) including the right:

To access the personal data held about you and request a copy of it;
To ask us not to process your personal data for marketing purposes;
To withdraw at any time any consent you have given to receive marketing material from us, or in any other case where we process your personal data on the basis of a consent that you have given (and not on some other legal basis);
To ask us to rectify inaccurate personal data about you;
To ask for the restriction of personal data about you that is inaccurate, unlawfully processed, or no longer required;
To ask for the transfer of your personal data in a structured, commonly used and machine-readable format where appropriate;
To ask for the erasure of personal data about you where processing is no longer necessary or the legitimate interests we have in processing your personal data are overridden by your interests, rights and freedoms as the data subject; and
To make a complaint to a supervisory authority (see below).

Changes to this Privacy Notice

We may change this Data Protection Notice from time to time. In the case of any substantial change, we will notify you (where practicable) in writing or by email.

Contact us

If you have any questions or comments about this Privacy Notice, or you wish to exercise your rights under Data Protection legislation then please contact our Data Protection Manager, as follows;

By Email: DataProtection@inceco.com

By Post:
Data Protection Manager,
Ince & Co., Aldgate Tower, 2 Leman Street,
London, E1 8QN, United Kingdom

Lodging a complaint with a supervisory authority

You may have the right to lodge a complaint to a supervisory authority about the processing of your data by an Ince affiliate. Contact details, where available, can be found below.

United Kingdom

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

T: 0303-123-1113
W: www.ico.org.uk

Greece

Hellenic Data Protection Authority
1-3 Kifissias Avenue
Athens
115 23
Greece

T: (+30) 210-6475600
W: www.dpa.gr

Hong Kong

The Office of the Data Privacy Commissioner for Personal Data
12/F Sunlight Tower
248 Queen’s Road East
Wanchai
Hong Kong

T: (+852) 2827-2827
W: www.pcpd.org.hk

Cyprus

Office of the Commissioner
for Personal Data Protection
Iasonos 1
1082 Nicosia
Cyprus

T: (+357) 2281-8456
W: www.dataprotection.gov.cy

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