Regulatory, Data Policy, Disclaimer, Copyright Notice, Licence to Copy or Re-Copy

Regulatory 

Warwick Legal Network Limited (WLN) is registered in England under No. 7104157 as a company limited by guarantee.
WLN's registered office is at Camburgh House, 27 New Dover Road, Canterbury, Kent CT1 3DN, England.
See:  https://beta.companieshouse.gov.uk/company/07104157 

WLN is an international association of independent law firms. 
WLN does not give legal advice in any form, but our member firms are appropriately regulated in the jurisdiction(s) where they have offices and/or are admitted to practise.  Please refer to the website of the individual WLN member firm you may be dealing with for further information.  A geographical list of WLN's member firms appears at:  https://www.warwicklegal.com/wln-members 
EORI (Economic Operator Registration and Identification) number: GB026257724000

 Disclaimer
The material contained in this Warwick Legal Network Limited ("WLN") Web Site (“the Site”) does not constitute legal or other professional advice, should not be treated as such and is provided for general purposes only.
WLN tries to ensure that the content of this Site is accurate and up-to-date, but all users should seek appropriate legal advice before taking or holding back from any action. We accept no responsibility for loss which may arise from reliance on information contained in this Site or other sites which may be linked to our Site from time to time.
Any opinions, advice, statements, services, offers, or other information that constitutes part of the content of our Site expressed or made available by third parties are those of the respective authors or distributors and not of WLN, its employees or agents. The content available through the Site represents the opinion and judgment of the respective author; WLN neither endorses nor is responsible for the accuracy or reliability of any such opinion, advice or statement made on the Site.

Copyright Notice
The contents of these pages are © Warwick Legal Network Limited. Reproduction is permitted only in accordance with the licensed terms below. In any event the copying of any article is only permitted if it is copied in full with no amendment or editing. Translation is permitted on the basis that you take full responsibility for the accuracy of the translation.

Licence to copy for personal use
You may print copies of any item in hard copy for your personal use or for use by others within your organisation. You may also download any item to a local hard disk, provided such download is for your personal use or access by others within your organisation.

Licence to recopy for limited purposes
The supply of any copy to a third party is permitted for their personal use provided that:

• You acknowledge to the third party that the WLN web page is the source of the material including the WLN web address (www.warwicklegal.com) in the copy of the material;
• You tell the third party that these licence conditions apply to him and he must comply with them;
• You do not supply the copy as part of another work or publication; and
• You do not supply the copy directly in return for commercial gain.

Please send any requests to reproduce materials outside the scope of this licence to Thomas Schneider.

GDPR:  Data Policy & Privacy Statement
(hereinafter “Privacy Policy”)
Warwick Legal Network Limited (hereinafter “WLN”, “we”, “us”, “our”) is a company, registered in England, by Companies House under No. 07104157, as a company limited by guarantee without share capital. WLN's registered office is at Camburgh House, 27 New Dover Road, Canterbury, Kent CT1 3DN, England. For detailed information, see: https://beta.companieshouse.gov.uk/company/07104157
You can contact us by e-mail: Manager@warwicklegal.com
Our website (including all subpages, hereinafter “Website”): www.warwicklegal.com

 WLN is a non-profit company, an international network of independent law firms, whose sole purpose is to service the law firms (hereinafter “Member Firms”) connected to WLN. WLN does not give legal advice in any form, but our member firms are appropriately regulated in the jurisdiction(s) where they have offices and/or are admitted to practice.

 This Privacy Policy applies to the Personal Data that WLN collects and processes. Personal Data is to be understood as any information relating to an identified or identifiable natural person. Whereas, identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 It is important that you read the Privacy Policy, so that you are fully aware of how and why we are processing your Personal Data, as well as aware of your rights.
The WLN website is not intended for children (under the age of 12) and we do not knowingly collect data relating to children.

1. PURPOSE OF THIS PRIVACY POLICY AND PERSONAL DATA COLLECTING
WLN respects your privacy and is committed to protecting your Personal Data. We have made every effort to ensure the maximum protection of Personal Data processed through the Website.  The processing of the Personal Data occurs in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter “GDPR”) and relevant UK laws. This Privacy Policy aims to give you information on how WLN collects, controls, handles, in general processes your Personal Data. Whereas processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We process your Personal Data for the following purposes:
1. proper provision of the Website as a whole for the use by its users;
2. proper provision of Website services in reference to employees, workers, contractors, agency workers, consultants, directors, partners, members and others, from the Member Firms professional profiles posted on the Website;
3. proper provision of Website and other services, including e-mail communication with regards to WLN’s services and/or other activities,
4. making sure the Website meets the needs of its users, as well as introducing improvements.

2. CONTROLLER
WLN is the data controller and responsible for your Personal Data processed with the use of the Website and all its subpages. Where these pages link out to services provided by third parties, they are managed separately by each service provider and their own privacy policies will apply.  WLN does not have a Data Privacy Officer (DPO), but our Managing Director(s) is (are) appointed as “data privacy manager” and is (are) responsible for overseeing questions in relation to the Privacy Policy. If you have any questions about the Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager via the e-mail address above. You can also contact the data privacy managers by e-mail or post, under the WLN addresses provided above, or using the “Contact Us” subpage on our Website.

3. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Privacy Policy under regular review and reserve the right to changes. You will be informed about the changes to our Privacy Policy on our Website. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed, if your Personal Data changes during your relationship with us or with a Member Firm.

4. THIRD-PARTY LINKS AND RECIPIENTS OF PERSONAL DATA
This website may include links to third-party websites. Clicking on those links 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 policy of every website you visit. Each time the Website is accessed, the user’s web browser automatically triggers the download of a redirection to another administrator's website in order to download data of another website, which is carried out by a plug-in from it. During this technical process, this entity is informed about, which specific subpage of the Website the user visited. External components integrated with the Website belong to: Twitter, Instagram, Facebook, LinkedIn, YouTube, Pinterest, Google+, Google Analytics and Google Adwords, Google+. These External components collect data in connection with the user’s account of the given social platform. Therefore, the data can be integrated with the user's account data and stored on it. The component informs about the visit of the user logged in to the user's social account on the Website. You can prevent this by logging out of your social account. The Website has integrated Twitter’s components. Twitter is an online social platform for virtual communication on the Internet. Twitter operator is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 USA, for Users outside the USA Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland. The data protection policy on Twitter is available at https://twitter.com/en/privacy.

Your Personal data is only made available to third parties through our website facility to find a lawyer with certain specifics and if your registered for a conference to the providers of services, such as hotels, restaurants or other venues that we use and to your fellow conference visitors. WLN may be required to provide information collected by the Website to authorized bodies on the basis of lawful requests to the extent resulting from the request. WLN has the right to transfer data to public authorities and entities professionally involved in the recovery of debts, if it is necessary to establish, assert or defend claims or as part of the administration of justice by courts. Some of the Personal Data may be provided by the Controller to entities technically performing certain services related to the operation of the Website and WLN. This entails the hosting companies (De Hosting Makelaar, with its seat in The Netherlands) and the IT web site service provider (Loyals with its seat in The Netherlands).

5. THE DATA WE COLLECT ABOUT YOU
Personal Data, does not include data where the identity has been removed (anonymous data). We may process different kinds of Personal Data about you, depending on the relation between us, which we have grouped together as follows:
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
• Usage Data includes [information about how you use our website, products and services].
And
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
• Identity Data includes [first name, maiden name, last name, username or similar identifier, title, date of birth, gender and your profile photo].
• Contact Data includes [billing address, delivery address, personal email address and telephone numbers].
• Profile Data includes [your username and password, preferences, feedback and survey responses].

 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

 We do not collect any Special Categories of Personal Data about you, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation shall be prohibited.

6. IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect Personal Data by law, or to process complaints, reservations, or requests regarding the Website and/or WLN services, or under the terms of a contract we have with a Member Firm and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with the Member Firm and/or process complaints, reservations, or requests. In this case, we may have to cancel a product or service the Member Firm has with us or leave a matter unanswered.

7. HOW IS YOUR PERSONAL DATA COLLECTED?
Depending on the relation we have with you, we use different methods to collect data from and about you including through:
• Directly from you or the Member Firm, in case of Personal Data such as Identity and Contact, by filling in data collection forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you
o apply for our products or services (f.i. register for a conference);
o create an account on our website;
o subscribe to our service or publications;
o request marketing to be sent to you;
o enter a competition, promotion or survey; or
o give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

8. LEGAL BASIS FOR THE PERSONAL DATA USE
We will only use your Personal Data when the law allows us to. Depending on the relation you have with us, we process your Personal Data on the following legal basis:
• You have given your consent to our processing of your Personal Data for one or more specific purposes (art. 6 (1) (a) of GDPR).
• Where we need to perform the contract we have entered into with you or in order to take steps at the your request prior to entering into a contract (art. 6 (1) (b) of GDPR).

 If, we process your Personal Data on the consent base as a legal basis, have the right to withdraw consent at any time by contacting us. However, withdrawal of the consent may lead to preventing us from providing the services for which the consent has been obtained and does not affect the lawfulness of processing based on consent before the withdrawal.

 9. EXERCISING YOUR RIGHTS
Please note that:
• You have the right to access to your Personal Data that we process
You have the right to obtain from us confirmation as to whether or not your Personal Data are being processed, and, where that is the case, access to the Personal Data and the following information:
(a) the purposes of the processing;
(b) the categories of Personal Data concerned;
(c) the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;
(d) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;
(e) the existence of the right to request from us rectification or erasure of your Personal Data or restriction of processing of the Personal Data or to object to such processing;
(f) the right to lodge a complaint with a supervisory authority;
(g) where the Personal Data is not collected from you, any available information as to their source;
(h) the existence of automated decision-making, including profiling, referred to in art. 22 (1) and (4) of GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing;
(i) if applicable, on the safeguards pursuant to art. 46 of GDPR relating to the transfer of the Personal Data to third country or to an international organization.  We shall provide you with a copy of your Personal Data undergoing processing, if requested. However, for additional further copies requested, we may charge a reasonable fee based on administrative costs.

 • Right to rectification
You have the right to obtain from us, without undue delay the rectification of inaccurate Personal Data concerning yourself. Taking into account the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement. You can change/update your Personal Data on the Website yourself by using your personal login. If you lost your login details, then please inform us as soon as possible. If you suspect that an unauthorized person altered your personal login, then you should inform us as soon as possible, to enable us to take necessary measures.

 • Right to erasure (‘right to be forgotten’)
You have the right to erasure of your Personal Data without undue delay and we will be obliged to erase your Personal Data without undue delay where one of the following grounds applies:
(a) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) you have withdrawn your consent on which the processing is based and where there is no other legal ground for the processing;
(c) you have objected to the processing pursuant to art. 21 (1) of GDPR and there are no overriding legitimate grounds for the processing, or you have objected to the processing pursuant to art. 21 (2) of GDPR;
(d) the Personal Data have been unlawfully processed;
(e) the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;
(f) the Personal Data have been collected in relation to the offer of information society services referred to in art. 8 (1) of GDPR. Where the Personal Data has been made public and we are obliged to erase them, taking account of available technology and the cost of implementation, we shall take reasonable steps, including technical measures, to inform controllers which are processing the Personal Data that you have requested the erasure by such controllers of any links to, or copy or replication of those Personal Data. The above shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject to, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of art. 9 (2) as well as art. 9 (3) of GDPR;
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with art. 89 (1) of GDPR, in so far as the right referred to above, is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defense of legal claims.

 • Right to restriction of processing
You have the right to obtain from us restriction of processing where one of the following applies:
(a) the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data;
(b) the processing is unlawful and you opposes the erasure of the Personal Data and request the restriction of their use instead;
(c) we no longer need the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
(d) you have objected to processing pursuant to art. 21 (1) of GDPR pending the verification, whether our legitimate grounds override yours.  Where processing has been restricted, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

• Right to data portability
You have the right to receive your Personal Data, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance, where:
(a) the processing is based on consent pursuant to point (a) of art. 6 (1) of GDPR or point (a) of art. 9 (2) of GDPR, or on a contract pursuant to point (b) of art. 6 (1) of GDPR; and
(b) the processing is carried out by automated means.
 In exercising the portability right, you shall have the right to have the Personal Data transmitted directly from one controller to another, where technically feasible.

 • Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data, which is based on point (e) or (f) of art. 6 (1) of GDPR, including profiling based on those provisions. We shall no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Where Personal Data are processed for direct marketing purposes, you have the right to object at any time to processing Personal Data for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the Personal Data shall no longer be processed for such purposes. Where Personal Data are processed for scientific or historical research purposes or statistical purposes pursuant to art. 89 (1) of GDPR, on grounds relating to your particular situation, you have the right to object to processing of your Personal Data, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

• Automated individual decision-making, including profiling
WLN does not profile you or your Personal Data.

• The right to complaint to the supervisory authority and court
If we fail to undertake action in relation to the your request, we shall immediately inform you - not later than within one month of receipt of the request - about the reasons for not taking action and about the possibility of submitting a complaint to the supervisory authority and the use of legal protection measures before a court.

Without prejudice to other administrative or legal protection measures before a court, you may lodge a complaint with a supervisory authority, in particular in the Member State of you habitual residence, place of work or place of alleged infringement, if you think that the processing of your Personal Data violates laws of GDPR. For U.K. the Information Commissioner’s Office (ICO), is the UK supervisory authority for data protection issues (www.ico.org.uk) and can be contacted using the following details:
casework@ico.org.uk
Telephone: 0303 123 1113
Textphone: 01625 545860
Monday to Friday, 9am to 4:30pm

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

 You also have the right to lodge a complaint to a court against the decision of the supervisory authority. Without prejudice to available administrative or legal protection measures before a court, including the right to lodge a complaint with a supervisory authority, you have the right to an effective remedy before a court, if you believe that you rights under the GDPR have been violated as a result of processing of your Personal Data. Proceedings against the Controller should be brought about before the court of the Member State in which the Controller has its registered office, i.e. England. Alternatively, such proceedings may be instituted before a court of a Member State in which you have your habitual residence.

 10. DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. You accept and agree though that the published data on our website may be copied or stored by others. This is an element of the publication we have no control over.  We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. DATA RETENTION
 We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.