Clément Konrad & Partners S.à.r.l Luxembourg Law Firm - Privacy Policy

Clément Konrad & Partners S.à.r.l (“Clément Konrad”, “we”, “us”, or “our”), acting as a data controller, collects data to operate effectively and provide you (any data subject in relation with Clément Konrad) with the best services. At Clément Konrad your privacy is a priority. The present Privacy Policy has been designed to address how Clément Konrad may collect, use, share, protect and keep information about you as well as the rights to which you are entitled.

 

Information to be collected by Clément Konrad

In relation to its activity, Clément Konrad needs to collect and process certain information about you. The data collected depends on the context of your interactions with our law firm, the choices you make including the services which are provided to you.

When Clément Konrad requests personal data, such request may be declined, in such case Clément Konrad may not be able or deny to deliver the service.

 

Processed personal data

Data collected and processed may include the following, amongst thus

  • - Identification data: contact data such as your first and last name, email address, postal address, phone number, and other similar contact data, date and place of birth, gender, country, nationality, preferred language, tax residency, relatives;
  • - Business contact information: profession, function, department, organization name, size, fiduciary relations, working contract situation;
  • - Financial information: information such as financial and bank accounts, bank, Know Your Customer (“KYC”) information;
  • - Contractual information: information allowing Clément Konrad to perform its contractual duties.

 

Data collection procedure

Personal data may be collected in various ways.

Unless required by the law and with the consent of the concerned person, no specific data such as personal information specifying criminal offences/convictions, medical or health conditions, biometric or genetic data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual shall be collected by us.

We collect data through cookies when you are using our website:

  • - Navigation and click-stream data;
  • - HTTP protocol elements;
  • - Search terms;

Personal data collection when doing business with Clément Konrad: information relating to an identified or identifiable natural person that Clément Konrad receives on behalf of the client himself/herself/itself.

Personal data collection from other sources: it may periodically be obtained both personal and non-personal information about you from business partners and other third-party sources where they are legally permitted to share such information with us, and include e.g. updated business address information, identification data, financial information, and contractual information.

Personal data collection for jobs application: please refer to the specific section below.

For processing to be lawful under REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 - the General Data Protection Regulation (“GDPR”) - , a lawful basis needs to be identified before processing personal data.

 

Use of your personal data

Clément Konrad uses or may use your personal data for the following purposes (or as otherwise described at the point of collection) in line with the lawful basis under the GDPR:

  • - Providing service you have requested;
  • - Performance of a contract;
  • - Providing information, access to resources or other services that you have requested from us on behalf of your organisation;
  • - Transmission of client service-related communications (marketing);
  • - Dealing with communications sent to Clément Konrad and responding to queries, requests and complaints;
  • - Complying with legal obligations in respect to Anti Money Laundering (“AML”)/KYC/Market Abuse Regulation (“MAR”);
  • - Managing the infrastructure and business operations of Clément Konrad and complying with internal policies and procedures;
  • - Compliance with any applicable rules, laws and regulations, codes of practice or guidelines or assistance in law enforcement and investigations by relevant authorities;
  • - Treatment of client communications sent to Clément Konrad and responding to queries, requests and complaints.

 

You may be contacted by mail, telephone, fax, video conference, email or other electronic messaging service to notify you about special events, new features or other information that may be of interest to you in accordance with your interaction with Clément Konrad. Where required by applicable law, your prior consent will be obtained before sending you direct marketing and you may object or opt out of receiving marketing messages from Clément Konrad.

 

Clément Konrad will not in any way sell, lease or rent your information to third parties.

 

Disclosure of your personal data

Depending on the nature and scope of our assignment, mandate or the service requested from us, Clément Konrad may with your consent disclose your personal data with the following recipients to the extent that such disclosure or transmission is deemed reasonably necessary or desirable for rendering any service you have requested or authorized:

  • - our lawyers, employees, service providers, agents, external consultants or other persons acting on our behalf;
  • - information technology service providers;
  • - accountants;
  • - advisers;
  • - auditors;
  • - fiduciary firms/domiciliation agents;
  • - administration and public authorities;
  • - banking institutions;
  • - notaries;
  • - correspondent law firms;
  • - tax advisors;
  • - law enforcement;
  • - government agencies;
  • - courts;
  • - co-investors;
  • - your direct and indirect shareholders;
  • - your ultimate beneficial owners;
  • - administrative bodies;
  • - regulatory bodies;
  • - governmental bodies ;
  • - judicial bodies;
  • - notaries public;
  • - bailiffs;
  • - legal directories.

 

The above list is construed so as to include any authorised employees, agents or other persons acting on behalf of the mentioned entities or bodies.

Those recipients may be located in and outside the European Union. Your personal data will not be transferred to any country outside the European Union which does not ensure an adequate level of protection unless you gave us prior authorization to do so or specific measures (such as adequate contractual arrangements) have been taken by us in order to ensure that the requirements of the applicable data protection law have been fulfilled.

Clément Konrad’s policy is to maintain contracts with all third parties with whom personal information is disclosed/transferred. Service providers must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.

 

Access to personal data

Clément Konrad wants to ensure that you can always exercise your rights. Clément Konrad will address any request within the limits of its technical and organizational means as soon as possible.

These include:

  • - Right to access your personal information: if you want to review the data we hold, collect and process about you, please let us know by contacting us;
  • - Right to rectification: should the data we hold, collect and process about you be inaccurate or incomplete, you have the right to update such data at any time by contacting us;
  • - Right to erasure: if at any time you decide you do not want us to retain any personal data we collected from you, you may request we delete your data by contacting us, unless required by the applicable laws;
  • - Right to restriction of processing: if you wish to exercise this right, please contact us , you may obtain the right to restriction of processing only if allowed by applicable laws;
  • - Right to object: if you wish to exercise this right, please contact us. Clément Konrad will consider your objection and we will comply with it unless there is a compelling legitimate ground as permitted by applicable law;
  • - Right to data portability: Your personal data may be transmitted directly from us to another controller only when you have asked us to do so and have consented to such sharing, and when technically feasible. If you wish to exercise this right, please contact us;
  • - Right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”), where you believe that your data is being processed in a way that does not comply with the GDPR.

 

How Clément Konrad protects your personal data

Clément Konrad commits to protecting the data you provide to us, in accordance to applicable laws. Appropriate organisational, physical and technical security measures (personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, encryption of personal data) are being implemented to protect against unauthorised or accidental access, loss, alteration, disclosure or destruction of personal data.

Notification in case of a personal data breach

Any personal data breach by Clément Konrad, its processors, or any other third-parties acting on Clément Konrad’s behalf will be notified without undue delay, and where the data breach is likely to result in a high risk to the rights and freedoms of the concerned person.

Changes to this policy

Clément Konrad reserves the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and used practices, and to ensure it is accurate, complete and up-to- date. You are advised to check this data protection policy from time to time.

Job applications

Personal data may be submitted through the use of our website to be considered for employment at Clément Konrad, amongst others, your name, your address, your phone number, your email address, experience, education, job skills and other information contained on your curriculum vitae (CV) and/or your cover letter. Clément Konrad utilizes that data solely for consideration of your candidacy, to communicate with you and to generate related correspondence, including offer letters and employment agreements, the data may also be used, subject to applicable local laws, to conduct necessary checks of background for compliance and other employment related purposes (including profile assessment in view of the conclusion of a potential employment contract, to the extent legally permitted. Finally, Clément Konrad only retains such data for as long as is necessary to address your employment application and for questions that may arise regarding your application’s processing. Your submission of personal data or a resume through our website constitutes your express consent to the collection, storage and use of that information by Clément Konrad during the recruitment process.

Retention period of personal data

Clément Konrad will only retain your personal data:

  • - For as long as it is necessary for the purpose or purposes for which it was intended;
  • - For the purposes of performing or fulfilling a contractual obligation with you or the organization that you represent and, therefore, legitimate business purposes;
  • - For as long as required or permitted by law.

 

How to contact us

If you have any questions or concerns about our use of your information or regarding our Privacy Policy, you may contact us by sending an email to info@ckpartners.lu or by writing to us at:

Clément Konrad & Partners S.à r.l.

Data Protection Officer

1 rue Schiller

L-2519 Luxembourg

Grand Duchy of Luxembourg

 

 

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