Privacy Policy for TLP Advisory (United Kingdom)

1. Introduction

tlpadvisory.com is provided by TLP Advisory (“TLP”). TLP is an international legal practice providing services to clients in various jurisdictions through separate and distinct legal entities, operating under the collective brand name, TLP Advisory. At TLP, we value your privacy and we are committed to safeguarding your personal information. All personal data that you provide us will be protected and kept confidential among our affiliates, representatives, and privies. Throughout the website, the terms “we”, “us” and “our” refer to TLP. This Privacy Policy is specifically for our United Kingdom law firm and explains how we collect, use, share and protect the personal data of citizens of the United Kingdom in connection with their relationship with us as clients, potential clients, consultants and partners. You agree to this Privacy Policy by visiting our website and when you use our services. Your use of our services, and any dispute over privacy is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Policy. Our website and services are not directed at you if we are prohibited by any law of any jurisdiction from making the information on our website available to you and is not intended for any use that would be contrary to local law or regulation.

2. How we collect and use your personal data

1. In this Section 2 we have set out:
   1. the general categories of personal data that we may process;
   2. the purposes for which we may process personal data; an
   3. the legal basis of the processing.
2. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is to provide our services and to monitor and improve our website and services.
3. We may process the information included in any onboarding form we send you to complete ("profile data"). The profile data may include your name, address, telephone number, email address, details of your company and the services you require. The profile data may be processed for the purposes of providing you with our services and communicating with you. The legal basis for this processing is your consent and the performance of a contract between you and us.
4. We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and providing you with detailed information on our services. The legal basis for this processing is your consent to access our services.
5. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is for the proper administration of our website and business and communications with our users.
6. We may process any of your personal data identified in this policy where necessary for [the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
7. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Please do not supply any other person's personal data to us, unless you have obtained such person’s consent to do so.

3. Disclosures

1. We may disclose your personal data to any member of our affiliate entities (this means our other law firms in Nigeria, the United States of America and Canada) insofar as reasonably necessary for the purpose of providing you with our services.
2. We may disclose your personal data to third parties that we engage when providing you with our services. We will obtain your consent before disclosing your personal data to such third parties and the processing of your personal data by such third parties shall be governed by a written contract with TLP to ensure adequate protection and security measures are put in place by the third party for the protection of your personal data.
3. We may also disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to (a) conform with the requirements of the law or comply with legal process served on us, or (b) act in urgent circumstances to protect the personal safety of users of our service or members of the public. To the extent practicable and legally permitted, we will attempt to advise you prior to any such disclosure, so that you may seek a protective order or other relief limiting such disclosure.
4. If you submit content in a public forum or a social media post, or use a similar feature on our website, that content is publicly visible and accessible.

4. Information We Collect.

1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom.
2. We have offices and facilities in Nigeria, the United States of America and Canada. Transfers to each of these countries will be protected by appropriate data protection safeguards and laws and shall be in compliance with the United Kingdom’s adequacy regulations.

5. Data Retention

1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose while providing you with our services shall not be kept for longer than is necessary for that purpose.
3. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Your Rights

1. Your principal rights regarding our use and processing of your personal data include:
   1. the right to access;
   2. the right to rectification;
   3. the right to erasure;
   4. the right to restrict processing;
   5. the right to object to processing;
   6. the right to data portability;
   7. the right to complain to a supervisory authority; and
   8. the right to withdraw consent.
2. You have the right to confirmation as to whether or not we process your personal data, where we do, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Provided the rights and freedoms of others are not affected, we will provide you with a copy of your personal data when you require us to do so.
3. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
4. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: where the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
5. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances include: where you contest the accuracy of the personal data; processing is unlawful; we no longer need the personal data for the purposes of our processing; and you have objected to processing. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6. You may exercise any of your rights in relation to your personal data by sending an email to info@tlpadvisory.

7. Use of Cookies

We use cookies to identify you as a user and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies allow our servers to remember you when you visit our website, IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities. If your browser or browser add-on permits, you have the choice to disable cookies on our website; however, this may limit your ability to use our website.

8. Website Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as secure sockets layer (SSL) to safeguard and secure the information we collect online. We use encryption tools when accepting and transmitting delicate visitor information through our website. Some of the other safeguards we use are firewalls and physical access controls to our data centres, and information access authorization controls.

9. Data Breach Management Procedure

1. In the event where there is any accidental or unlawful destruction, processing, loss, alteration, unauthorized disclosure of, or access to your personal data, we shall:
1. notify you within 24 hours of the occurrence of the data breach;
2. properly investigate the breach and take the necessary steps to mitigate such breach;
3. identify remediation requirements and track the resolution of such breach; and
4. notify appropriate regulatory authorities, where necessary.

10. Links to Third Party Websites

1. Our website may contain links to third-party websites or services that are not owned or controlled by us.
2. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services.
3. We strongly advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.

11. Limitation of Liability

We exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, we will not be liable for unauthorised disclosure of personal data that occurs through no fault of ours.

12. Changes to this Privacy Policy

Changes may be made to this Privacy Policy from time. Whenever such changes are made, we will notify you. These changes will take effect immediately after you have been notified.

13. Contact Us

If you would like more information or you have any comments or questions on our privacy policy, please contact us at [email protected].

This policy is effective from 27/10/2021 and was last updated on 26 October 2021.