Advokat Lexner AB strives to protect your personal integrity and any personal data that we are processing is processed in accordance with applicable data protection legislation. This policy describes how we process personal data regarding our clients, partners and employees and it is applicable within our whole organization.
DEFINITIONS
- Personal Data means any information that directly or indirectly can be used to identify a natural person. Such identifiers can be, for example, a name, address, telephone number or an identification number. In some cases, Personal Data is classified as sensitive and it is then Processed with extra care. Sensitive Personal Data can, for example, be information regarding health, political opinions and religious beliefs.
- Processing means any operation or set of operations which is performed, wholly or partly, by automated means, on Personal Data, such as collection, transmission and storage of Personal Data.
- Controller means the natural or legal person that determines the purposes and means of the Processing of Personal Data. The Controller is responsible for the Personal Data it is Processing and shall ensure that the Processing is secure and correct.
- The Swedish Bar Association’s Code of Conduct means the Code of Professional Conduct for members of the Swedish Bar Association (Sw. Advokatsamfundets vägledande regler om god advokatsed).
WHEN IS PERSONAL DATA COLLECTED?
- Personal Data can be collected when natural persons, such as clients, clients’ representatives, business partners, consultants, counter-parties, suppliers or sales persons contact us by telephone, our website or email. Personal Data can also be collected on visits to our office.
- Personal Data can the collected in connection with assignments that we are performing or when we receive applications for employment, trainee spots or internships. Normally Personal Data is collected from the natural person to whom it belongs. However, in some cases we may also collect Personal Data from private or public records or third parties. When deemed necessary we may also supplement or verify Personal Data that has been collected through private and public records or sources.
- When we are in contact with our business partners or suppliers, we may collect Personal Data about natural persons at the other company or regarding other third parties.
WHICH PERSONAL DATA IS COLLECTED?
- If you contact us by telephone, email or if you visit our offices, we may collect your contact details such as your name, title, workplace, telephone number and email address as a part of that communication.
- While administering an assignment or in relation to an ongoing business relationship we will collected the Personal Data that is necessary in order for us to fulfil and complete a given assignment. We will also collect any Personal Data that is shared with us during the preparation and administration of such an assignment. Personal Data that can be collected are, for example, contact details, identification numbers, economic information and invoice details.
- When we receive an application for employment, trainee spots or internships we will collect any Personal Data that is shared with us during the recruitment process. Such Personal Data may be contact details, date of birth, proficiency in languages, previous working experience, personal interests, academic achievements as well as contact details to references.
- Normally there are no obligations for you to provide us with any Personal Data that is requested. However, if you do not share such Personal Data with us we may be unable to accept or fulfil an assignment since we will be unable to comply with obligations under applicable law such as, for example, performing mandatory conflict of interests and money laundering checks.
WHY DO WE PROCESSES PERSONAL DATA?
- Personal Data that is collected regarding a client is collected and Processed in order for us to fulfil our contractual obligations, administrate given assignments and protect our client’s best interest. Any Personal Data that is collected and Processed about other natural persons, such as representatives, consultants or adversaries, during the administration of an assignment, is Processed based on our legitimate interest to Process Personal Data that is necessary in order for us to fulfil our and our client’s legitimate interest if we deem that such interest outweighs any opposing interests or rights.
- Personal Data is also collected and Processed in order for us to comply with our obligations in accordance with applicable law and The Swedish Bar Association’s Code of Conduct. Such obligations include, but are not limited to, performing mandatory conflict of interest and money laundering checks, archiving completed assignments and fulfilling our obligations issued in the Book-keeping Act.
- Personal Data that is collected and Processed in relation to our supplier and customer relationships is being Processed in order for us to fulfil contractual obligations and with regard to our legitimate interest. We also Process Personal Data in order to manage and maintain our business relations with our business partners, suppliers and other third parties.
- Personal Data may also be collected with regard to our legitimate interest to improve our business, for marketing analysis purposes, send out newsletters, secure Personal Data from fraud and other illegal activities, develop our security- and business systems and keep statistics for analyzes.
WHO HAS ACCESS TO THE PERSONAL DATA THAT IS BEING PROCESSED?
- We may give access to Personal Data if such access or disclosure is necessary in order to fulfil a client’s interests and it falls within the purpose of a given assignment and is in the best interest of the client.
- Access to Personal Data may be given to our suppliers or business partners if they are performing a service for us or are performing services on our behalf. Suppliers are not allowed to Process any of the Personal Data for their own purposes. They are only allowed to Process the Personal Data in accordance with our given instructions and in order to fulfil their contractual obligations.
- In some cases, we may be obligated to give access to Personal Data to comply with a legal obligation in applicable law, a decision by public authorities or obligations under The Swedish Bar Association’s Code of Conduct.
- Personal Data may also be disclosed if such disclosure is based on a given consent or is otherwise permitted by applicable law.
IS PERSONAL DATA TRANSFERRED OUTSIDE THE EU/EES?
- We may need to share personal data with our office in Moscow, the Russian Federation, if relevant for the particular matter in case. Any such transfer will be made in line with applicable data protection laws. Such transfers will only be performed if there exists an adequate level of protection, such that the recipient is certified to the “Privacy Shield Framework” or on the basis of the EU Commission’s standard contractual clauses.
WHICH ARE YOUR LEGAL RIGHTS AND HOW DO YOU GET ACCESS TO YOUR PERSONAL DATA?
- You have certain legal rights regarding the Personal Data that we, as a Controller, are Processing about you. These rights are:
- right to access –you have the right to know which Personal Data we are Processing about you, for which purposes it is being Processed, how long it will be Processed and if it is shared with any third party. You can request access to this information by contacting us, see Section 10 below for contact details.
- right to correction – you have a right to have incorrect and incomplete Personal Data corrected or completed.Such correction or completion shall be performed by us without undue delay.
- right to withdraw consent –you have the right to withdraw a given consent. A withdrawal does not affect the lawfulness of our Processing of Personal Data based on the consent before you withdrew it, but we will stop any further Processing of the Personal Data for the purpose that you originally consented to.
- right to object – if you find that your Personal Data is being Processed incorrectly you have a right to object to the Processing if the Personal Data has been collected in regard to our legitimate interest. Upon such an objection we will assess whether or not the Processing can continue.
- right to restriction – if you find that your Personal Data is being Processed incorrectly, you have the right to request that we restrict the Processing while an assessment is made whether or not we are entitled to continue the Processing. Such a restriction entails that your consent is required for any act of Processing other than our storing your Personal Data. You will be informed when the restriction is lifted.
- right to erasure – you have a right to request that we shall cease with all Processing and that your Personal Data shall be erased from our systems. We will perform such an erasure unless we are allowed to keep Processing the Personal Data in accordance with applicable law.
- right to data portability – you have a right to transfer your Personal Data to a third party. We will perform the transfer if your Personal Data is Processed by automatic means and it is technically possible. You will always receive the data in a machine-readable format that you can transfer on your own.
HOW LONG WILL WE STORE PERSONAL DATA?
- We do not store Personal Data for a longer period of time than what is necessary in order to fulfil the purposes for which the Personal Data is being Processed. However, Personal Data may be stored for a longer period of time if it is allowed or required in accordance with applicable law.
- Personal Data that is Processed and obtained during the performance of an assignment will be stored during the administration of such an assignment and 10 years after its completion in accordance with the requirements in The Swedish Bar Association’s Code of Conduct. If it is necessary due to the circumstances in a particular assignment, Personal Data may be stored for a longer period of time.
HOW DO WE USE COOKIES?
- Cookies are text files that stores data on a unit and recognizes an individual that visits our webpage. Through the settings in your browser you have the opportunity to decide whether or not you wish to accept that cookies are stored on your unit.
- On our website there has been placed two types of cookies, session cookies and statistical cookies. Some cookies have been placed by Google Analytics. Session cookies are only stored on your unit during the time your web session lasts while statistical cookies can be stored for up to two years. Cookies are placed on our website for the purpose of analyzing data traffic and the number of visitors on our website, including interactions with the website. This information is collected in order for us to understand your needs and develop our services.
CONTACT DETAILS
Advokat Lexner AB, Reg. No. 559153-6833, Törnrosvägen 41,181 61 Lidingö is the Controller regarding the Processing of Personal Data that is described above. If you want to receive more information regarding our Processing of Personal Data, if you wish to exercise your legal rights or if you have any complaints, kindly contact us by email sven.lexner@advokatlexner.com or by regular mail to the address above. If you have any complaints, you may also contact the Swedish Data Protection Agency (Sw. Datainspektionen).