Cox Hallett Wilkinson Limited and its affiliated service companies (known collectively as CHW) are committed to being a responsible custodian of the information you provide to us and the information we collect and use in the course of operating our business and providing legal and other services.
This Privacy Policy sets out how CHW may collect, use and share information and describes:
- The types of information, including personal information, we may collect and use;
- How we may use and share the information we collect;
- Legal grounds for using personal information;
- The measures we have in place to protect and safely store the information we collect;
- Retention of the information we collect;
- Your choices and rights in respect of the information we use;
- How to contact us;
- Complaints; and
- Changes to this Privacy Policy.
For the purposes of this Privacy Policy the utilization of the word “use” or “using” in relation to personal information takes on the meaning provided by the Personal Information Protection Act 2016 which is, carrying out any operation on personal information, including collecting, obtaining, recording, holding, storing, organising, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating or otherwise making available, combining, blocking, erasing or destroying it. The words “collect” or “collecting” and “process” or “processing” are to be interpreted in accordance with the General Data Protection Regulation or GPDR.
The types of information, including personal information, we may collect and use
We collect and use your personal information when you provide it to us. “Personal information” is any information that can be used to identify you or that we can link to you as an individual and may include:
- Your full name, date of birth, passport, driving licence or other photo identity details;
- Company or organisation details;
- Contact information including postal address, residential address, email address and telephone numbers;
- Information pertinent to fulfilling our legal services on an individual’s or organisation’s behalf.
We also use sensitive personal information when you provide it to us. “Sensitive personal information” is any personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual preferences, marital status, physical or mental disability, physical or mental heath, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information.
For the purposes of this Privacy Policy the utilization of the “personal information” includes sensitive personal information.
Personal information you provide to us voluntarily
We may also collect and use other information that you voluntarily provide to us, including when you communicate with us via email, post, telephone or other channels, including but not limited to applications for employment; signing up for an event that we host; and when you respond to our communications or requests for information.
Information we may collect and use from third party sources
We may receive information about you from other sources, including third parties and publicly available information that helps us: identify new customers or prevent or detect fraud. We may also receive information about you from social media platforms. Please note that the information we may receive from those social media platforms is governed by the privacy settings and policies of those platforms, and we strongly encourage you to review them before submitting any information to them.
How we may use the information we collect
We may use the information we collect:
- To respond to your enquiries;
- To provide you with the legal and other services that you request;
- To send you alerts and legal updates, marketing communications and other information or materials that may be of interest to you or which you have expressed an interest in receiving;
- To maintain our list of contacts;
- For our business purposes, including improving the provision of our services, submitting invoices, detecting or preventing fraud or illegal activities;
- To evaluate and recruit personnel; and
- As we believe is reasonably necessary or appropriate to comply with our legal obligations, respond to legal process or requests for information issued by government authorities or regulatory agencies; or to protect your rights, our rights or others’ rights.
How we may share the information we collect
Cox Hallett Wilkinson Limited and its affiliated service companies share information with each other for business purposes such as billing, internal administration, promoting our events and services, and providing you with legal services. We will not sell, rent or otherwise share any information with unaffiliated entities except as expressly described in this Privacy Policy, or with your prior permission. We may share anonymised information that does not identify you or your organisation only as permitted or required by applicable law.
We may share the information we collect with:
- Employees of CHW but their use shall be limited to the performance of their duties. Our employees are required to keep that information confidential and are not permitted to use it for any purposes other than to provide the services which you have contracted with us; and
- Law enforcement, courts or tribunals, other government authorities, regulatory authorities or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us; as provided for under contract; or as we deem necessary to provide our services. In these circumstances, we will take reasonable efforts to notify you before we disclose information that may identify you or your organisation, unless giving prior notice is prohibited by applicable law or is not possible in the circumstances.
Legal grounds for using personal information
We rely on the following legal grounds to process and use personal information, namely:
- Consent: We may use personal information as described in this Privacy Policy subject to your consent. If you wish to withdraw your consent to such use, you can contact us via the Contact Us page on our website.
- Performance of a contract: We may need to collect and use personal information to enter into a contract with you or to perform a contract that you have entered into with us. For example, when you engage CHW to provide legal services we will use your personal information to correspond with you and to provide you with such services.
- Legal obligations: We may need to collect and use personal information to comply with legal obligations to which CHW is subject. This includes undertaking client due diligence and background checks (known as “know your client” or KYC checks) as well as all anti-money laundering or other legal obligations.
- Legitimate interests: We may use your personal information for our legitimate interests to provide legal or other services and to improve our services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use personal information for our marketing purposes and other technical information as described in this Privacy Policy.
Measures we take to protect and safely store the information we collect
CHW is located only in Bermuda, and your data is stored in Bermuda.
We deploy administrative, technical and physical safeguards designed to comply with applicable legal requirements and best practices to safeguard the information that we collect and use. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by CHW.
However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.
Retention of the information we collect
We retain the information we collect and use for no longer than is reasonably necessary to fulfil the purposes for which we collect and use the information and to comply with our legal obligations specified in the relevant Bermuda legislation.
Your choices and rights
To withdraw your consent to the use of your information as described in this Privacy Policy you can contact us via our Contact Us page on our website. Please note that in some circumstances this may mean that we can no longer provide our services to you.
If you no longer wish to receive marketing communications from us, you can let us know by sending us an email via our Contact Us page.
You have a number of rights in relation to your personal information that we collect and use. These rights include:
- the right to access your personal information that we collect and use, and to obtain information about how we use and process it;
- the right to withdraw your consent to our use of your personal information, which you can do at any time. We may continue to use your information if we have a legitimate reason or legal obligation for doing so;
- in some circumstances, the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party;
- the right to request that we rectify your information if it is inaccurate or incomplete;
- in some circumstances, the right to request that we erase or destroy your personal information. We may continue to retain your personal information if we are entitled or required to use it and we will provide written reasons as to why the continued use of such personal information is justified;
- the right to request that we restrict our use of your personal information in some circumstances. There may be situations where you object to or ask us to restrict our use of your information but we are entitled to continue using your personal information and/or to refuse that request.
You can exercise your rights by contacting us using the details set out below. As an individual you also have a right to complain to the data protection regulator in the country where you reside or work.
If you would like to discuss these rights, you can contact us via our Contact Us page.
How to contact us
We welcome your enquiries and comments. Please note that if you are not a client, we may not be able to treat the information you send us as confidential or privileged. If you wish to contact us regarding legal or other services, please contact the Head of the Department that you wish to engage.
If you would like to contact us with questions about our Privacy Policy or data protection practices, please send us an email via our Contact Us page or by writing to:
The Privacy Officer
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Complaints
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to complain to the data protection authority/regulator in your jurisdiction. The details for the Bermuda authority/regulator are as follows:
Office of the Privacy Commissioner
Maxwell Roberts Building, 4th Floor
1 Church Street
Hamilton HM 11
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Changes to this Privacy Policy
We may update this Privacy Policy from time to time and we encourage you to review this page periodically. If we make any material changes in the way we 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 CHW website (www.chw.com).