Your privacy is important to us. This Privacy Policy explains how we handle and treat your data when you (i) register or visit our website, www.lprotopapa.com or associated sites or pages (the "Site") or (ii) engage with us to use the products or services (either online or not) that L. PROTOPAPA & CO LLC provides  (the "Services"). It also includes information about individuals whose personal information we may process as a result of providing the Services to third parties and individuals who apply to work at L. PROTOPAPA & CO LLC.

1. Introduction

This Privacy Policy explains how we collect and use information that we obtain about you, and your rights in relation to that information. Your use of our Services or your provision of information to us constitutes your acknowledgment of the terms of this Privacy Policy. Please do not send us any of your information if you do not want it to be used in the ways described in this Privacy Policy.

Our contact details are set out at section 12 below.

2. Scope of privacy policy

This Privacy Policy applies when we receive any personal information from you, our clients or other third parties, including in the following circumstances:

• when you request information from us or provide information to us;
• when you or the Organisation you work for engages our Services;
• when you or the Organisation you work for are a counterparty, or provide services to a counterparty, of one or more of our clients;
• as a result of your relationship with one or more of our clients, including when You or the Organisation you work for is a Regulator, Government Agency, Court, Tribunal or other Law Enforcement Agency;
• when you apply for a role or work placement opportunity, interview day or recruitment event with us;
• when you complete any application forms on our Site;
• when you attend our seminars or other hosted events;
• when we conduct open source searches on you in connection with our business acceptance or business development processes;
• when you visit our Site and online services (including our mobile apps); and
• when you are entered onto our mailing lists to receive publications and other marketing emails (please see section 10 for more information).

3. Information collection

PERSONAL DATA THAT WE COLLECT

"Personal data" is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The personal data that we collect, and how we collect it, depends upon how you interact with us.

Categories of personal data that we collect include:

• Contact information such as name, address, email address, telephone number and I.D. number.
• Biographical information such as job title, employer, photograph and video or audio content.
• Marketing, communication preferences and related information such as feedback and survey responses.
• Billing and financial information such as billing address, bank account and payment information.
• Services information such as details of services that we have purchased from you.
• Information relating to children or regarding criminal matters.

PERSONAL DATA THAT WE COLLECT FROM YOU

We collect personal data directly from you as follows:

• When you sign up to register for one of our online Services, we will ask you provide your contact and other relevant information, as well as your communication preferences.
• When you register to attend one of our events, we will ask you to provide your contact, guest and other relevant information.
• When you use our Site or our online Services, we collect information about your visit and how you interact with our website.
• When you use our legal Services, we will ask for the information that we need to provide those Services; this information includes contact details, billing information, information necessary to conduct pre-clearance checks and information relevant to the Services we provide. Information provided by a client may include personal data that relates to persons whose information is relevant to the instruction; for example, when we advise on a business transaction or a regulatory investigation or represent a client in a legal dispute.
• When you apply for a job with us, we will ask you for information relevant to your application.
• If you provide information to us about another person, you must ensure that you comply with any legal obligations that may apply to your provision of the information to us, and to allow us, where necessary, to share that information with our service providers.

Information we collect from third parties:

Most of the personal data that we collect about you will be information that you provide to us voluntarily. In some circumstances we may also receive information from:

• other entities belonging to our group
• our clients, when we handle personal data on their behalf
• regulatory bodies
• credit reference agencies
• other companies providing services to us.

Some of these third-party sources may include publicly available sources of information.

We may also receive information about you from Google Analytics, a web analytics service provided by Google, Inc. ("Google") whose servers are in the United States of America. Google Analytics uses cookies to help us analyse how users use our Site. 

4. Use of your information

We may use your personal information if:

• it is necessary for providing you or the organisation you work for our Services; or necessary in connection with a legal or regulatory obligation; or

• you have provided your consent (where necessary) to such use or the organisation that you work for has obtained your consent (where necessary); or
• we (or a third-party) have a legitimate interest which is not overridden by your interests or your rights and freedoms; or
• we are otherwise required or authorised by law.

We may use your information to:

• provide and improve our Services to you or the organisation you work for (including auditing and monitoring use of those services and products);
• maintain and develop our relationship with you and our clients;
• monitor and analyse our business;
• facilitate our internal business operations;
• fulfil our legal, regulatory (including in relation to anti-money laundering or sanction requirements), accounting, reporting, risk management or professional obligations;
• identify services you may be interested in;
• send you legal updates, publications, marketing and details of events;
• protect, establish, exercise or defend legal rights; and
• process and respond to requests, enquiries or complaints received from you.

We may not be able to do these things without your personal information.

We will only retain your personal information for as long as is reasonably necessary in the circumstances. Personal information provided in connection with the provision of our Services will be retained for a period of 10 years.

5. Disclosure of your information

We may share your information with third parties including:

• your professional advisers and your employers or place of business;
• third parties involved in the provisions of Services to you including counterparties,  other lawyers that are involved as counterparties to the Services, the Court and other professional advisers; 
• our professional advisers, auditors and insurers;
• third party service providers to whom we outsource services, for example archival, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), IT support, website, social media, research, banking, payment, client contact, data processing, insurance, litigation support, marketing and security services;
• third party technology organisations;
• third parties who carry out research and analyses of our services and products on our behalf; or
• regulatory authorities, courts, tribunals, government agencies, law enforcement agencies and other third parties.

Where we transfer your information internationally, we will take reasonable steps to ensure that your information is treated securely, and the means of transfer provides adequate safeguards.

All of your personal information will be stored with and managed by us on a private server that we keep in house.

If you have any questions in relation to the transfer of your personal information, please contact us at dpo@lprotopapa.com

6. Security

We take reasonable steps to hold information securely in electronic or physical form and to prevent unauthorised access, modification or disclosure. Our information security policy is supported by a number of security standards, processes and procedures and we store information in access-controlled premises or in electronic databases requiring logins and passwords. All partners and staff and third-party providers with access to confidential information are subject to confidentiality obligations.

7. Cookies

Our Websites use "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services.  Please see our Cookie Policy for details.

8. Third party sites

Our Website may contain links to other sites which are controlled by third parties.

Visitors should consult these other sites' privacy policies and please be aware that we do not accept responsibility for their use of information about you.

9. Your rights

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following:

• Right to be informed: you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing.
• Right of access: you have the right to request a copy of the personal data that we hold about you.
• Right to rectification: you have the right to verify the accuracy of your information and ask for it to be updated or corrected.
• Right to erasure ("right to be forgotten"): you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; this would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
• Right to restrict processing: you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it.
• Right to object: you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent;
• Rights in relation to automated decision making and profiling: you have the right not to be subjected to a decision based solely on automated processing.

While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to defend our legal rights or meet our legal and regulatory obligations.

If you contact us to exercise any of these rights, we will check your entitlement and respond in most cases within a month.

If you are not satisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to the relevant Supervisory Authority (Data Protection Commissioner at www……………………………).

10. If you do not wish to receive marketing information from us 

If you receive marketing materials relating to our Services by email or post, you may withdraw your consent for us to send these to you at any time, by using the “unsubscribe” option included in the email or other material. Alternatively, you can let us know your preferences by sending an email to dpo@lprotopapa.com.

11. Status of this Policy

We review this Privacy Policy regularly and reserve the right to revise it or any part of it from time to time to reflect changes in the law or technology practices. It is the responsibility of the user to review the amended Privacy Policy.                                                                 

12. Contact and further information

To find out more about L. PROTOPAPA & CO LLC entities, please visit www.lprotopapa.com

Furthermore, we are also required to take reasonable steps to ensure that your personal data remains accurate. In order to assist us with this, please let us know of any changes to the personal data that you have provided to us by contacting us at dpo@lprotopapa.com.

If you have any questions about this Privacy Policy, or want to submit a written complaint to us about how we handle your personal information, please contact us at: