Augustine Clement (“We”) are committed to protecting and respecting your privacy. This privacy statement (together with our terms and conditions and any other policies referred to in it) explains what information we gather about you, what and how we use that information, the lawful basis on which that information is used and who we give that information to. It also sets out your rights and our obligations in relation to your information and who you can contact for more information or queries.
Who this privacy statement applies to and what it covers
This privacy statement sets out how we will collect, handle, store and protect information about you when providing services to you or our clients, or performing any other activities that form part of the operation of our business.
This privacy statement also contains information about when we share your personal information with third parties (for example, third parties carrying out activities on our behalf). In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
We understand the importance of protecting children’s privacy. It is not our policy to intentionally collect or store information about children unless required for us to carry out your instructions.
What information we collect
We may collect and process personal data about you because you give it to us, because other people give that data to us (for example, our client has provided to personal data for the purpose of a transaction or litigation of which you are a party, or because it is publicly available.
The personal data that we collect or obtain may include: your name; age; date of birth; gender; e-mail address; home address; country of residence; employment and education details (for example, the organisation you work for, your job title and your education details); details of how you like to interact with us and other similar information.
We may collect and process personal data about you that you give to us, as follows:
- If you provide information to us by filling in forms on our website or by filling in application form. This may include information provided at the time of registering with us or applying for a position in our firm or requesting further services.
- Details of transactions and litigation we have carried out on your behalf.
- We may ask you for information when you report an issue or concern or we have or receive a complaint or query from you (whether or not a formal dispute is raised).
- We may keep a record of correspondence between you and us.
- We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of the messages you send and receive via emails or text including without limitation, when you sent or received a message and the contents of that message. Messages are not private and are not confidential.
We may collect and process personal data about you from other sources as follows:
- We sometimes supplement the information that you provide with information received from third parties. For instance, credit reference agencies, search information providers, other parties to a transaction or litigation, other companies (subject to their privacy policies and applicable law).
- Where we are provided with personal data about you by any third party, we take steps to ensure that that third party has complied with the privacy laws and regulations relevant to that information; this may include, for example, that the third party has provided you with notice of the collection (and other matters) and has obtained any necessary consent (if applicable) for us to process that information as described in this privacy statement.
We collect personal data about our prospective, current and former employees (including interns) as follows: basic identification information, such as your name, title, position, professional history, experience, and contract details.
For current employees, we usually collect in addition to the above:
- Detailed identification information including passport numbers, right to work documentation, private email and/or postal address and country of residence.
- Electronic identification data (e.g. email address, login information).
- Education and employment information (e.g. remuneration, bonuses, insurance and other benefits information, employment dates, position information such as title, attendance information including, where relevant, illness or leaves of absence for medical or other reasons, language skills and education details , pensions information including entitlements and recruitment information including job applications, CVs, job history and references.
- Financial information (e.g. bank account details, and tax-related information).
- National Insurance number.
- In some cases, the personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your: health (for example, so that we can make reasonable accommodations for you in our buildings, and services) and sexual orientation (for example if you provide us with details of your spouse or partner).
- The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
Use of personal data
We will use your personal data to fulfil your requests and we will ask only for data that is adequate, relevant and not excessive for those purposes. Where we send you information for any purpose, it may be sent by e-mail or post. When we ask you for personal data it may include the following purposes:
- We may contact you occasionally to inform you of new services we will be providing;
- We may send you regular updates on issues we think will be of interest to you;
- We may send you requested information on our services;
- We may use your personal data for marketing purposes and market research;
- We may use your personal data internally to provide you with the services offered and to help us improve our services.
- We may use your personal data for managing and making information available to third party service providers (e.g. or in order to support our information technology) and our affiliates.
- We may use your personal data to notify you about changes to our services, terms and conditions, policies or website.
- We may use your personal data to manage risk, or to investigate, detect, prevent, and/or remediate fraud, suspected fraud or other potentially illegal or prohibited activities.
- We may use your personal data pursuant to applicable legal or regulatory requirements or to respond to requests and communications from competent authorities (including courts and tribunals).
- We may use your personal data for the services we receive from our professional advisors, such as lawyers, accountants and consultants.
- We may use your personal data for protecting our rights, those of our clients, or protecting those of our affiliates. None of the information that we request from you is mandatory. However, where such information is not provided to us, We may be unable to identify, protect, or return your money or assets.
The legal grounds we use for processing personal information
We are not allowed to process personal information if we do not have a valid legal ground. Therefore, we will only process your personal information for the purposes outlined above because:
- of our legitimate interests in the performance of activities that form part of the operation of our business;
- of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests or fundamental rights and freedoms;
- of the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
- the information is required in order to carry out the activities that form part of the operation of our business(e.g. the processing is necessary to perform our contractual obligations towards you or to take any preliminary steps in determining whether to enter into any contractual obligation).
To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti money laundering’ obligations (or other legal obligations imposed on us); (ii) the processing is necessary to carry out our obligations under employment, social security law; (iii) the processing is necessary for the establishment, exercise or defence of legal claims; or (iv) you have made the data manifestly public.
We may, from time to time, e-mail or post you information to make you aware of our other similar services which may be of interest to you. If you do not wish to receive emails or post from us for these purposes, or if you want to be removed from our electronic mailing list you can either select “unsubscribe” from any of the marketing emails that we send or alternatively contact us.
Augustine Clement is a registered “Data Controller” under the Data Protection Act 1998.