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SAYENKO KHARENKO PRIVACY POLICY

(Effective 25 May 2018)

Sayenko Kharenko takes your privacy seriously and is committed to respect and safeguard it.

This policy describes:

  • who is the data controller under this policy and how you can contact us
  • what information we may collect and process about you
  • how we may obtain your personal information
  • how we may use your personal information
  • on what basis we use your personal information
  • how long we keep your personal information
  • how we may share your personal information with third parties
  • which countries we may transfer your personal information to
  • your rights regarding your personal information
  • changes to this privacy policy

Please read this policy carefully to be clear how SK will treat your personal information.

WHO IS THE DATA CONTROLLER UNDER THIS NOTICE AND HOW YOU CAN CONTACT US?

Sayenko Kharenko Ukraine LLC, Sayenko Kharenko Attorneys’ Office, Sayenko Kharenko Law Firm LLC and our affiliated business (collectively, “Sayenko Kharenko”, “SK”, “we”, or “our”) are controllers of your personal data.

If you have any questions or concerns regarding our treatment of your personal data, please contact us at: dataprotection@sk.ua. Our office location is 10 Muzeyny Provulok, Kyiv 01001, Ukraine.

WHAT INFORMATION WE MAY COLLECT AND PROCESS ABOUT YOU?

We may collect and process personal information from you in the course of our business, including through your use of our website; when you communicate with us via email or other channels; when you sign up for or request that we send you newsletters, alerts, or other materials; when you sign up for a webinar, meeting, conference, or event; when you submit an application for a position with us; when you engage our legal or other services or as a result of your relationship with one or more of our staff and clients; and when you respond to our communications or requests for information.

The personal information that we may collect and process includes:

  • Basic information, such as your name (including name prefix or title), the company you work or worked for, your title or position and your relationship to a person, your photo placed at your employer’s / contractor’s website or social media (for our CRM system);
  • Contact information, such as your postal address, email address and phone number(s);
  • Financial information, such as payment-related information;
  • Technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically;
  • Information you provide to us for the purposes of attending meetings and events;
  • Identification and background information provided by you or collected as part of our business acceptance processes;
  • Personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data.

HOW WE MAY OBTAIN YOUR PERSONAL INFORMATION?

Personal information you provide to us

We collect and process personal information from you as part of our business acceptance processes and about you and others as necessary in the course of providing legal services.

Information we may collect automatically

Visiting our website does not require you to provide any personally identifiable information, such as your name, address, e-mail address or phone number. When you visit our website, we automatically collect certain information, which, however, does not allow us to identify you. This information may include the following:

Browsing statistics

Sayenko Kharenko collects information about the websites’ content mostly viewed by the visitors, frequency of the connections to the website, software and hardware exploited to visit our website, geography of our visitors. This information enables SK to understand the manner how the visitors work with our website. In order to obtain such information we employ Google Analytics (the detailed information about this tool is available here). You may disable any data collections by this tool at your discretion as instructed here.

We rely on our legitimate interest to provide customized services and better our content when collecting your browsing statistics.

Logs

The hardware of our website hosting provider may record requests made by the visitors to the website, the information on software and hardware exploited to visit our website, IP address assigned as well as timing related to access. We use this information to enhance the security of our website.

We rely on our legitimate interest to ensure security of our website when collecting your logs data.

Cookies

A cookie is a text string that SK website transfers to the cookie file of the browser on your computer so that the website can remember your preferences. You may find more information about cookies here. We use cookies data to analyze visitor’s behavior and improve user’s experience. You may disable cookies by your browser settings or by clicking here.

We rely on our legitimate interest to ensure technical functionality of the website when collecting your cookies data.

Information we collect from other sources

We may receive information about you from other sources, including third parties that help us: update, expand, and analyze our records; identify new customers; or prevent or detect fraud. We may also receive information about you from social media platforms including but not limited to when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform, and we encourage you to review them.

HOW WE MAY USE YOUR PERSONAL INFORMATION?

Sayenko Kharenko collects and processes personal information about you in a number of ways, including through your use of our website and in the provision of services by us. We use that information:

  • To respond to your requests;
  • To provide you with legal and other services that you request;
  • To provide and improve this website, including auditing and monitoring its use;
  • To manage and administer our relationship with you and our clients including to receive feedbacks and maintain our list of contacts;
  • To promote our services, including sending legal updates, publications and details of meetings, events, and seminars;
  • To assess the quality of our legal services and the effectiveness of our events, promotional campaigns, and publications;
  • To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims; protecting your, our, or other’s rights;
  • For the purposes of recruitment.

ON WHAT BASIS WE USE YOUR PERSONAL INFORMATION?

We use your personal information on the following bases:

  • To perform a contract, such as engaging with an individual to provide legal or other services.
  • For the establishment, exercise or defense of legal claims or proceedings.
  • To comply with legal and regulatory obligations.
  • For legitimate business purposes. Please see ‘How we use your personal information’ for more detail.
  • Consent – where required by applicable laws, we will rely on your consent for direct marketing.

HOW LONG DO WE STORE YOUR PERSONAL INFORMATION?

SK will retain collected personal information as long as necessary to fulfil the purposes for which it was collected and processed. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data collected, the potential risk of harm from unauthorised use or disclosure of it, the purposes for which we process personal data and whether we can achieve those purposes through other means and applicable legal requirements.

Upon expiry of the applicable retention period, we will securely destroy personal data collected.

HOW WE MAY SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?

We may also share your personal information with certain third parties in accordance with contractual arrangements in place with them, including:

  • Our professional advisers, auditors, potential transaction partners.
  • IT service providers to Sayenko Kharenko including providers of cloud services and client relationship management (CRM) services. In particular, we currently engage Bpm’online, Inc. for providing CRM services.
  • Third parties engaged in the course of the services we provide to clients and with their prior consent, such as legal counsels outside Ukraine and technology service providers like data room services.
  • Third parties involved in hosting or organising meetings, events or seminars.

Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies.  While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.

If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to new Sayenko Kharenko’s entities or to third parties through which the business of Sayenko Kharenko will be carried out.

We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.

WHICH COUNTRIES WE MAY TRANSFER YOUR PERSONAL INFORMATION TO?

In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this privacy policy. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA.  Please see ‘Who we share your personal information with’ for more detail on how the information may be shared with third party service providers.

The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws including without limitation EU standard contractual clauses.

YOUR RIGHTS UNDER THIS POLICY

Contacting us via e-mail at dataprotection@sk.ua you may exercise your right:

  • request access to your personal data and request information in relation to its processing;
  • request rectification of your personal information;
  • request erasure of your personal information;
  • request restriction of processing of your personal information;
  • object to the processing of your personal information;
  • withdraw your consent (if any is given);
  • lodge a complaint in relation to Sayenko Kharenko’s processing of your personal information with a local supervisory authority. Contact information of the local supervisory authority can be accessed at http://www.ombudsman.gov.ua/en/page/applicant/

You may exercise your rights in accordance with applicable data protection laws.

If personal data is erased at your request, SK will only retain such copies of the information as are necessary to protect our or third party legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with SK.

Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘How we use your personal information’) or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

MINOR’S DATA PROCESSING

Our site is neither directed nor targeted to individuals under the age of 18. If you are under the age of 18, do not provide us with any personal information. If we learn that someone under 18 has provided personal data at our website, we will erase it immediately.

LINKS

Our website may contain links to third-party websites. SK is not responsible for the privacy practices or the content of such websites.

CHANGES TO THIS POLICY

We reserve the right to update this policy from time to time. Therefore, we encourage you to periodically review this page. If we make any material changes in the way we collect, use, and/or share the personal information that you have provided, we will notify you by posting notice of the changes in a clear and conspicuous manner on the Sayenko Kharenko website.