Published 27 January 2021
1 – PURPOSE OF THIS PRIVACY NOTICE
1.1 This website privacy notice (“‘Privacy Notice”‘) is issued by Withers LLP, Withers Bergman LLP and their affiliated partnerships, offices, undertakings, affiliates and alliances, includingWithers BVI, Withers 衛達仕, Studio Legale Associato con Withers LLP, Withers KhattarWong LLP, Withers Japan, Zeirishi Jimusho and Withers Tax Advisory LLP authorised to practice under the name ‘Withers’ or ‘Withersworldwide’ together the (“Withers Group”) (and references to ‘Withers’, ‘we’ or ‘us’ are to one or more of those partnerships, offices and undertakings, as appropriate). It provides you with information on how we collect and process your personal data through your use of this website (“Website”), regardless of where you visit it from.
1.2 We reserve the right to revise this website Privacy Notice at any time so please check that you have seen the latest version by visiting this page regularly.
2 – CONTROLLER
2.1 The Withers Group is made up of different legal entities and this Privacy Notice is issued on behalf of the Group so when we mention “Withers”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant entity in the Withers Group responsible for processing your data. Under the EU General Data Protection Regulation (“GDPR”) and UK Data Protection Act 2018 (“DPA”), Withers LLP is acting as ‘controller’ and has primary legal responsibility for any personal data you submit through this Website.
2.2 Withers LLP is currently registered in the United Kingdom as a fee payer with the Information Commissioner’s Office (“ICO”) (number: Z6371171).
3 – THIRD-PARTY LINKS
3.1 This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
4 – THE DATA WE COLLECT ABOUT YOU
4.1 We may collect personal data from you if you use this Website. For example, when you supply your contact details to sign-up to receive alerts, register for events or request other information from us.
4.2 Provision of your personal data is voluntary but failure to provide certain personal information requested may render you unable to use or access certain services or parts of this Website.
4.3 The type of personal data we require will be set out on the relevant page of the Website at the time you register with us and may include your name, email address, postal address and other personal details about you. This personal data relating to you is referred to in this Privacy Notice as ‘Your Information’
5 – HOW WE USE YOUR INFORMATION
5.1 We will only use Your Information when the law allows us to and in the following circumstances:
(a) providing you with access to our Website and personalising your visit to our Website;
(b) administering, supporting, improving and developing our business and services;
(c ) dealing with your enquiries, instructions or issues you raise with us;
(d) providing you with information by email, phone or mail about services which are similar to services you previously received from us;
(e) letting you know about new legal developments;
(f) providing you with alerts, newsletters and information about events or conferences;
(g) seeking your participation in surveys or research by email, phone or mail;
(h) modifying and improving our Website;
(i) dealing with job applications, as referred to in section headed ‘Job Applications’ and
(j) responding by email, phone or mail to your requests for more information regarding our legal, regulatory services and advisory services.
We have a legitimate business interest in processing Your Information for the reasons set out in 5.1(a) – 5.1(j).
We may also contact you for other purposes that you consent to from time to time.
You have a right at any time to stop us from contacting you for direct marketing purposes.
If you wish to unsubscribe from receiving marketing communications from us please email us at email@example.com.
6 – TRUSTS AND ESTATES
For more details regarding how Withers LLP, and its wholly owned trust corporation, Withers Trust Corporation Limited may use personal data in connection with its trusts and estates work, please see the ‘Privacy notice for trust and estate beneficiaries’.
7 – JOB APPLICATIONS
7.1 You have the ability, through this Website, to apply online for a training contract or other employment vacancy with Withers. This process is managed by a third party data processor acting on our behalf and when clicking on the relevant link you will be taken to their dedicated mini-site which is used solely for the purpose of dealing with your application to Withers.
7.2 To apply for a training contract or other employment vacancy, you will have to fill in an online application form which will require you to provide biographical details, including details of your education and employment history and other similar information relevant to the recruitment decision-making process. This information that you submit will enable us to make a decision as to whether to proceed with your application.
7.3 Please note that when you apply for a position with us, you guarantee and warrant to us that the information that you provide to us is true, accurate and complete in all respects.
7.4 As part of the application process, you may also be asked to provide details of your ethnic origin or state of health (which we call ‘sensitive information’). This is so that we can maintain our commitment to being an equal opportunities employer. When you fill in the online form, you will be given the choice as to whether or not you want to disclose this sensitive information. You are completely free not to disclose such sensitive information and this will have no influence whatsoever on the outcome of your application. If you do provide such sensitive information in your application, it will only be used for equal opportunities monitoring and for no other purpose.
8 – WHO WE SHARE YOUR PERSONAL INFORMATION WITH
8.1 Your Information may be shared with other entities in the Withers Group and the web-hosting provider for the purposes described in this Privacy Notice. Please click here for a full list of the Withers Group entities and the countries in which they are established.
8.2 Personal data including Your Information we hold will usually only be shared with third parties, such as our service providers, if the following apply:
(a) they require the personal data for the purposes of providing specific contracted services;
(b) you have been made aware of such sharing of Your Information and, if needed, your consent has been obtained, or an alternative lawful basis for such processing has been satisfied;
(c ) where acting as a ‘controller’, the third party has agreed to comply with appropriate data security standards, policies or procedures; or where acting as data ‘processor’ under our instructions, that third party is subject to a written contract that contains relevant security requirements and other obligations to protect Your Information in accordance with applicable law; and
(d) where required, the transfer complies with any applicable cross-border transfer restrictions.
However, we may occasionally need to disclose Your Information to third parties where we are legally required to do so and cannot tell you, for example, in order to comply with a court order or regulatory obligation.
9 – INTERNATIONAL TRANSFERS
9.1 Please note that because of the international scope of our business, to enable us to provide legal services, it may be necessary to transfer Your Information provided or collected from within the European Union (‘’EU”) to a jurisdiction outside of the EU. The level of protection for personal information available in jurisdictions outside of the EU may be lower than the standards applied within the EU or the jurisdiction where you live. Whenever we transfer Your Information outside of the EU, to a territory that does not meet EU approved standards, unless a legal exemption applies, we will ensure appropriate measures are in place to protect Your Information in accordance with applicable EU data protection law.
10 – PROTECTING YOUR INFORMATION
10.1 We employ appropriate technical and organisational security measures to protect Your Information from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.
10.2 We also endeavour to take all reasonable steps to protect Your Information from external threats. However, please be aware that there are inherent security risks of sending information by public networks or on public computers and we cannot therefore 100% guarantee the security of any data disclosed or transmitted over the internet.
11 – HOW LONG YOUR INFORMATION WILL BE KEPT AND YOUR RIGHTS
11.1 Our document and records retention schedules (and criteria for determining how long we hold personal data, including without limit, Your Information) are based on our statutory obligations and our business purposes, activities or needs. Destruction of records may be suspended if it becomes apparent that there is possibility of a claim, anticipated litigation or regulatory investigation that means such data may have to be retained.
11.2 You may have the following legal rights under data protection law (subject to certain legal exemptions and restrictions) in respect of Your Information that we hold:
(a) request that we give you access to a copy of it;
(b) request that we rectify or update it, if inaccurate;
(c ) request that we erase it, in certain circumstances where it is no longer needed;
(d) request that we restrict our use of it, in certain circumstances
(e) object to our using it, in certain circumstances;
(f) withdraw your consent to our using it (where our processing is based on your consent);
(g) a right to data portability, in certain circumstances;
(h) request us not to use it for direct marketing; and
(i) lodge a complaint with the data protection regulator or supervisory authority in your country (if there is one). In the UK, the relevant authority is the Information Commissioner’s Office (“ICO”). In Italy, the relevant authority is the Garante per la Protezione dei Dati Personali (‘Garante’)
For more information about the ICO, the above data rights and how to lodge a complaint, please visit the ICO website.
For more information about the Garante, the above data rights and how to lodge a complaint, please visit the Garante website.
12 – CHANGES TO THIS PRIVACY NOTICE
This Website Privacy Notice was last updated on 27 January 2021. It may be amended or updated from time to time, so please check that you have seen the latest version.
13 – HOW TO CONTACT US
13.1 Please contact us and/or our Data Protection Office by post, email or telephone if you have any questions about this Privacy Notice or the information we hold about you.
13.2 Our contact details are shown below:
- Post: Data Protection Office, 20 Old Bailey, London EC4M 7AN
- Email: firstname.lastname@example.org
We may need further information to verify your identity before we can fully respond.
14 – COOKIES
14.1 Cookies are small pieces of information, normally consisting of just letters and numbers, which online services provide when users visit them. Software on the user’s device (web browser) can store cookies and send them back to the website next time they visit. Cookies are a specific technology that store information between website visits. They are used for various purposes, such as remembering what’s in a shopping basket when shopping for goods online, supporting users to log in to a website, analysing traffic to a website, and tracking users’ browsing behaviour.
14.2 Cookies can be useful because they allow a website to recognise a user’s device. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Without cookies, or some other similar method, websites may have no way to ‘remember’ anything about visitors, such as how many items are in a shopping basket or whether they are logged in. There are some other technologies, similar to cookies, which can also identify and ‘remember’ website visitors. These include, for example, using certain characteristics to identify devices (device fingerprinting), using scripts, tracking pixels, plugins and social media buttons. We collectively refer to these as ‘tracking technologies’.
14.3 Some tracking technologies, particularly those that track users’ browsing behaviour across different websites are perceived by data protection regulators as privacy-intrusive. We are, therefore, presenting this Cookies Policy to our website visitors in order to explain why and how we use this technology.
14.3 Our website uses the following types of technologies:
- Strictly necessary technologies. These technologies enable core functionality such as page navigation and access to secure areas. The website cannot function properly without these technologies, and can only be disabled by changing your browser preferences. Strictly necessary technologies are always ‘on’ by default.
- Preference tracking technologies. Preference technologies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
- Website Analytics. Such tracking technologies help us to improve our website by collecting and reporting information on its usage.
14.4 You can find more information about the technologies we use and the purposes for which we use them in the table below.
Specific tracking technologies in use:
|Google Analytics||3rd party integration||Google Inc||Analytics||
“_ga” – 24 months
“_gat” – 1 minute
“_gid” – 24hrs”
|Siteimprove||3rd party integration||Siteimprove||Analytics||“nmstat” – 1000 days||https://siteimprove.com/en/privacy/|
|Locations||Cookie||1st Party cookies||Functionality||“locationOverlay” – Session|
|Language||Cookie||1st Party cookies||Functionality||
js-language-confirm” – 1 month
“locale” – Session
“site_id” – Session”
14.5 In addition to the controls provided on our website via the pop-up, you can choose to block cookies by activating the settings on your browser that allow you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of the website. Your browser settings also allow you to delete all cookies stored on your device whenever you wish.
14.6 The UK Information Commissioner’s Office provides the following guidance on controlling cookies:
- A number of websites provide detailed information on cookies, including AboutCookies.org and AllAboutCookies.org.
- The European Interactive Digital Advertising Alliance website Your Online Choices allows you to install opt-out cookies across different advertising networks.
- Google has developed a browser add-on to allow users to opt-out of Google Analytics across all websites which use it. This is also available in the Chrome web store.
- Some browsers include a feature known as ‘Do Not Track’ or DNT. This allows you to indicate a preference that websites should not track you. However, whilst DNT is available in many browsers, websites are not required to recognise its request, so it may not always work. You can get help on how to use DNT in Microsoft Edge, Microsoft Internet Explorer, Mozilla Firefox, Google Chrome and Opera.
- For more information on how private browsing works as well as its limitations, visit the support pages for your browser: Microsoft Edge, Microsoft Internet Explorer, Mozilla Firefox, Google Chrome, Safari (IOS and desktop) and Opera.
14.7 If you are really concerned about online tracking then we can recommend you the below software solutions, however your use of such solutions is entirely at your own risk:
- Install a privacy-friendly browser on your device, such as Mozilla Firefox, Firefox Focus or Brave;
- Install anti-tracking and ad-blocking plug-ins on that browser, such as Ad Block Plus, Ghostery or PrivacyBadger; and
- Use privacy-friendly web search engines, such as DuckDuckGo or Ecosia.
14.8 If you have any questions about the cookies or similar technologies in use on our website or in the e-newsletter, please send us an email at GDPROffice@withersworldwide.com.