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Privacy Policy

1. Commitment to Privacy

1.1 Conyers Dill & Pearman and its affiliated entities including Conyers Client Services (collectively “Conyers”, “us” “our” and “we”) is committed to maintaining the security, confidentiality and privacy of your Personal Data.

1.2 “Personal Data” means information associated with a specific identifiable individual but does not include information about corporate or commercial entities.

1.3 This Privacy Policy documents our commitment to protecting your Personal Data.

2. Responsibility

2.1. Conyers is responsible for Personal Data in its possession or control. We have designated an individual to be responsible for compliance with this Privacy Policy and have adopted procedures to protect Personal Data, receive and respond to complaints, access requests and inquiries, train staff regarding policies and procedures and communicate our policies to you. We will monitor ongoing developments in privacy legislation and make changes to this policy as required.

2.2. For the purposes of the European Union’s General Data Protection Regulation and the Cayman Islands’ Data Protection Law, Conyers collects and processes Personal Data and acts as a data controller. In delivering our services to you, your Personal Data that is collected through our website or by any of our staff may be transferred between our servers and offices, including our data centre, which is located in Toronto, Canada. As such our various offices may act as joint data controllers of your Personal Data. Our London office acts as our European Union representative.

3. What we Collect

3.1. In addition to Personal Data provided to us by you through our staff or website, we may also collect information that is publicly available. The Personal Data we may hold includes:

(a) Contact information, including name, telephone number, address and email address;
(b) Occupation and employer details;
(c) Identification documents (which may include gender, nationality, photograph, signature, date of birth, etc.) and numbers necessary to meet our legal obligations, such as those related to anti-money laundering and “know-your-customer” requirements;
(d) IP addresses; and
(e) Details related to marketing our services, including recording your usage of our website and the mailing lists for which you have subscribed or unsubscribed.

4. Purposes

4.1. Conyers comes into the possession of Personal Data in order to provide professional services. Conyers only collects and processes Personal Data if it is lawful to do so, specifically where:

(a) it is required to fulfill a contract with you;
(b) it is required for us to comply with the law;
(c) it is necessary for us to perform a task in the public interest;
(d) it is necessary for our legitimate interests, or the legitimate interests of a third party; or
(e) you have provided us with your consent.

4.2. Your Personal Data may be used for the following purposes:

(a) to meet our regulatory, legal and professional obligations;
(b) to establish and manage our relationship with you;
(c) to provide legal advice and services;
(d) to monitor and manage the performance of our business operations;
(e) to manage conflicts of interest;
(f) to analyse performance, and generate internal reports;
(g) to assess risks including legal and financial risks;
(h) to invoice and process payments;
(i) to process applications for employment;
(j) to monitor visitor traffic to and usage of the Conyers website;
(k) to market our services;
(l) to engage in business transactions;
(m) to prevent fraud;
(n) to undertake network and information security activities; and
(o) for any other purposes for which we have your consent, or for which Conyers or its third parties have a legitimate interest.

4.3. Conyers collects and processes Personal Data in order to fulfil its contractual obligations with you and to meet our applicable statutory obligations.  If you decide not to provide us with necessary Personal Data this may prevent us from meeting our legal obligations, and therefore prevent us from performing our services for you.

5. Limits on Collection, Use, Retention and Disclosure of Personal Data

5.1. Conyers does not retain any more of your Personal Data than we believe is necessary for any of the purposes set out in this Privacy Policy or which is dictated by legal or professional requirements, and retain and destroy Personal Data in accordance with our Records and File Retention and Destruction Policy. We will destroy, erase or make anonymous documents or other records containing Personal Data as soon as it is reasonable to assume that the original purpose of obtaining and storing it is no longer being served by retention of the Personal Data or retention is no longer necessary for legal, business or professional purposes. We will take reasonable care when destroying Personal Data so as to prevent unauthorized access.

6. Transfer of Information

6.1. Transfers to Third Parties.  Conyers may, from time to time, use third parties in the course of conducting its business. Conyers will use reasonable efforts to ensure that third parties are bound by the terms of this Privacy Policy or a similar policy.

6.2. International Transfers.  Your Personal Data may be transferred to or accessed from countries that may not have data protection laws equivalent to those of your country.   Unless we have your consent to transfer your Personal Data, the transfer is necessary for the performance of a contract, for the establishment, exercise or defence of legal claims, or is otherwise permitted by applicable data protection and privacy laws, we will only transfer your Personal Data to a country considered to have an adequate level of protection.  If such a country does not have equivalent privacy laws, Conyers will ensure it has the appropriate safeguards in place; such safeguards may include binding corporate policies and procedures, standard contractual data protection clauses approved by applicable supervisory authorities, an approved employee code of conduct, or an approved certification mechanism.

7. Your Rights

7.1. Right to Access.  You have the right to request and obtain from us the details of your Personal Data and how it is processed, including the purposes of processing, whether it has been disclosed to third parties, and how long we intend to hold on to the data. Your information will be provided upon written request and we reserve the right to request authentication of identity in the event of such a request.

7.2. Right to Withdraw Consent.  Where you have consented to us processing your Personal Data, you have the right to withdraw that consent at any time. If we consider that the withdrawal of such consent will impede our ability to provide any service to you we reserve the right to terminate our service in the event of such a withdrawal.

7.3. Right to Accuracy/Rectification.  You have the right to request that we rectify inaccurate Personal Data concerning you.

7.4. Right to Object To or Restrict Processing.  You have the right to object to or request that we restrict processing your Personal Data if:

(a) you believe the Personal Data we hold about you is inaccurate;
(b) you believe the processing is unlawful but you oppose us erasing your Personal Data;
(c) we no longer need to process the Personal Data but you require it for the establishment, exercise or defence of legal claims; or
(d) you object to the grounds upon which we have determined that processing your data is legitimate.

We are required to comply with your request unless the processing is to meet the conditions of a contract, under a legal obligation, in order to protect the vital interests of an individual, or otherwise permitted under applicable law.

7.5. Right to Object to Processing for Direct Marketing.  You have the right at any time to object to the processing of your data for direct marketing purposes.

7.6. Right to Avoid Automated Decision Making.  You have the right not to be subject to a decision based solely on automated processing (i.e. a decision made without human involvement), including profiling, which produces legal or similarly significant effects concerning you, unless it is necessary for entering into, or the performance of, a contract between you and Conyers.

7.7. Right to Data Portability.  You have the right to receive your Personal Data in a machine-readable format and the right to have that information transferred to another data controller, where technically feasible.

7.8. Right to Erasure/”Right to Be Forgotten”.  You have the right to request for us to erase your Personal Data. We will fulfill this request provided that there are no legal requirements for us to continue processing your Personal Data.

7.9. Right to Raise Your Concerns.  Conyers has procedures in place to receive and respond to complaints or inquiries about our policies and practices relating to the handling of Personal Data. If you have any questions or concerns about your Personal Data or how it is being used by Conyers, you can contact our Chief Privacy Officer at the address below. If we are unable to satisfactorily address your concerns, you have the right to communicate with the relevant supervisory authority.

8. Accuracy

8.1. You are required to advise us of any changes that may impact the services we are providing. From time to time, you may be asked to verify or update your Personal Data.

9. Safeguarding Personal Data

9.1. Conyers protects the Personal Data in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal, in accordance with our information technology and security policies, which are reviewed and tested on a regular basis. Confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. Conyers will not be responsible for any loss or damage suffered as a result of a breach of security and/or confidentiality when information is transmitted by e-mail or wireless communication. We will take your use of a particular mode of communication as permission for us to communicate with you using the same mode of communication unless otherwise instructed by you.

10. Cookies and our Website

10.1. Our website uses cookies. Find out more about cookies, how we use them, and how to manage them below.

10.2. Cookies are small files that are downloaded onto your computer to help improve your browsing experience and enable us to evaluate how people use our website. We currently use a session cookie and a persistent cookie. The session cookie is temporary and stored on your computer only for as long as you visit our website. The persistent cookie is uploaded to your computer only after you check the “Remember Me” box and enables you to store information to more quickly access password protected portions of our website.

10.3. Most web browsers, including Chrome, Internet Explorer, and Safari accept cookies and allow you to control your cookie settings on your computer or other device. To control the use of cookies on your device, including deleting and blocking the cookies any website uses, including ours, access your browser settings.  You may also use the cookie management tool on our website to select your cookie preferences for our website. Please note that any changes may affect your ability to properly use our website.

10.4. Our website may from time to time contain links to third party websites. Conyers does not take responsibility for the privacy practices of any third party website. Please ensure you read the policies of any third party website you visit.

10.5. Third-party vendors, including Google, may use cookies to serve ads based on a user’s past visits to our website. Third-party advertising vendors, including Google, may show our ads on sites across the Internet based on your past browser history. This practice is commonly known as remarketing.

10.6. Most web browsers, including Chrome, Internet Explorer, and Safari accept cookies and allow you to control your cookie settings on your computer or other device. To control the use of cookies on your device, including deleting and blocking the cookies any website uses, including ours, access your browser settings.  You may also use the cookie management tool on our website to select your cookie preferences for our website. Please note that any changes may affect your ability to properly use our website.

10.7. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings. Alternatively, you can opt of out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. You can also opt out of being tracked by Google Analytics across all websites by visiting: http://tools.google.com/dlpage/gaoptout.


11. Contact Us

11.1. If you have any questions about this Privacy Policy or your Personal Data you may direct your inquiries in writing to the Chief Privacy Officer at privacy@conyers.com or write us at P.O. Box 666, Hamilton HM CX, Bermuda.

11.2. Conyers reserves the right to amend this policy from time to time without prior notice to you. Please check our website periodically at www.conyers.com to see if any changes have been made.

Last updated 03 October 2019.

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