This Privacy Policy (the “Policy”) describes how Rosling King LLP collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our website. Our website is hosted in the United Kingdom and this website is not intended for children and we do no knowingly collect data relating to children.

In this Policy when we refer to Rosling King LLP or “we”/“us”/“our”/”RK” we mean Rosling King LLP (CRN: OC334495). Our registered office is at 55 Ludgate Hill, London EC4M 7JW and we are authorised and regulated by the Solicitors Regulation Authority (www.sra.org.uk). We have appointed a data protection officer who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact them using the details set out below.

We respect your privacy and are committed to protecting your personal data.

We keep this Policy under regular review and we may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.

This Policy supplements other notices and privacy policies and is not intended to override them. If you are a client of ours, you should also consult the relevant section of our terms of business.

1. The information that we collect and where we get it from

1. “Personal information or personal data” is any information that can be used to identify you or that we can link to you and which we have in our possession or control. It does not include data where the identity has been removed (anonymous data).
2. We may collect and process personal information about you. This may include:
   1. Information that you provide to us
      We will process personal information that you give to us including when you email us or contact us through various channels as follows:
      1. When you sign up for our newsletters obtain legal services from us or when you contact us with queries or respond to our communications the personal information you provide may include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
      2. Information provided in connection with our provision of legal services
      3. If you seek an estimate of costs for legal work or become a client of RK, we will also need information to confirm your identity e.g. your date of birth, about your matter and circumstances as well as contact information for you, your personnel and other parties to the matter. The information that we need will be explained to you by our lawyers and/or set out in our letter of engagement depending on the nature of your matter but may include both personal data and special categories of data. You may also provide us with additional information that you consider relevant as part of your instruction. If you are not a client we may collect or receive your personal information because you are involved in one of our client’s matters.
   2. Recruitment application
      When you apply for a position with us you may provide us with personal information which may include your name, date of birth, nationality, education and qualification details, your gender, home address, telephone number and other details set out in your application.
   3. Information we otherwise collect about you
      We will also collect information about you when at events, when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our website. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our website. For information about how we use Cookies and the choices you may have, please see our Cookies Policy below.
   4. Information we obtain from other sources
      If you apply for a position with us we may collect personal information relating to past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you.
      If we collect or receive your personal information in the context of our provision of legal services we might receive information from third parties such as your employer, other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the legal services that we are providing to you or to our client.
      Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you.
3. If any personal data which you provide to us relates to any third party (such as a joint account holder or beneficiary), by providing us with such personal information you confirm that you have obtained any necessary permissions and consents from such persons to the reasonable use by us of their personal data in accordance with the above provisions.

1. How we use the information we collect

1. We will only use your personal information when the law allows us to. We may do the following with your personal information:
   1. use it to provide legal services to you;
   2. use it to engage in marketing and business development activity in relation to our legal services. This may include sending you newsletters, legal updates, marketing communications and other information that may be of interest to you. Further details of our marketing activities are set out below;
   3. where you have applied for a position with us, to review and process your job application;
   4. to comply with legal and regulatory obligations imposed upon us;
   5. use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
   6. record and monitor your use of our website or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
   7. use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business;
   8. use it to deal with any complaints or queries you may have;
   9. use it to prevent and respond to actual or potential fraud or illegal activities.
   10. to ensure that the services we provide to you continue to be the most appropriate services and that our website continues to be presented to you in the most effective and efficient manner;
   11. to verify your identity and the identity of any and all beneficial owners, persons of significant control, trustees, and trust beneficiaries and to conduct all appropriate anti-money laundering checks;
   12. to respond to any queries which you may raise with us.
2. We may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.

1. Grounds for using your personal information

1. We must have a lawful basis for processing your information. The lawful basis will vary on the circumstances of how and why we have your information but typical examples include:
   1. Consent – we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below);
   2. Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you;
   3. Legitimate interest – we may use your personal information for our legitimate interests, some examples of which are given above; and/or
   4. Compliance with law or regulation – we may use your personal information as necessary to comply with applicable law/regulation.
2. Under applicable law, we are required to verify the identity of all our clients, and, where relevant beneficial owners of such clients, for anti-money laundering purposes. We may do so by using an electronic verification system or by requesting you to provide suitable documentary evidence. The electronic verification we may carry out or the information we are required to gather may relate to you. or where relevant your directors, officers, shareholders, members and/or trustees and trust beneficiaries, and you will ensure that such persons are made aware that we may carry out such electronic verification and/or will comply with all requests we reasonably make in connection with our anti-money laundering responsibilities. If you fail to provide any information which we reasonably require pursuant to this paragraph, or we are unable to obtain such information, we reserve the right to cease providing services with immediate effect without penalty.

1. How we share information with third parties

1. We may share personal information with our international associate law firms. As a result, your personal information may be transferred to locations outside of the European Economic Area as well as within it for the purposes described above.
2. We may also share your personal information outside RK. This may include:
   1. Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, insurers, auditors, IT and communications and administration service providers.
   2. Third parties relevant to the legal services that we provide. This may include, but is not limited to, counterparties to transactions or litigation, other professional service providers, professional advisers, regulators, authorities, governmental institutions and stock exchanges.
   3. To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
3. Where we transfer your personal information to other countries (which may include countries outside the European Economic Area,) we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:
   1. with your prior written consent;
   2. the country to which we send the personal information may be approved by the European Commission; or
   3. the recipient may have signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal information, or

   In other circumstances, the law may permit us to otherwise transfer your personal information outside the European Economic Area. You understand and accept that other countries which your personal information may be transferred to may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to client information and that information can become subject to the laws and disclosure requirement of such countries. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.

1. l

   Marketing

1. If you become a client of RK, we may use your personal information to invite you to hospitality events or other selected events for clients and/or to send you information that we think may be of interest to you or your business. This is within our legitimate interests as a law firm to use your information in this way.
2. We may also use personal information about our professional contacts to invite them to hospitality events or other selected events and/or to send them information that we think may be of interest to them or their business. This is also within our legitimate interests.
3. If you attend our hospitality events or other selected events, we may include your name and the organisation for which you work on registration or attendee lists which are distributed at these events to other attendees, which may incude guest speakers and/or any joint hosts. We only ever provide your name and the organisation for which you work on such lists. We never include your contact details. If you do not wish your information to be included on such lists, please contact our Marketing team using the details below.
4. You will be given an opportunity to tell us whether or not you wish to receive direct marketing materials and communications from us either at the time you submit or provide your details to us and/or within the communication itself.
5. If you do not wish to receive any direct marketing material or communications after you submit or provide your details, please contact our Marketing team using the details below (stating UNSUBSCRIBE in the heading of any email message) indicating if you do not wish to be contacted for one or more of these marketing purposes and/or via particular forms of communication e.g. email or telephone. Please note that the preferences that you state will override any registrations you or your organisation may have with the relevant preference organisations (such as the telephone preference services).
6. If you change your mind about being contacted by us in the future, or change address, or if any information that we hold about you is inaccurate or out-of-date, please let us know by: emailing: rkevents@rkllp.com or writing to our Marketing team at: Rosling King LLP or calling us on 020 7246 8000 and asking for the Marketing team.

1. Keeping your information and information security

1. How long we hold your personal information for will vary and will depend principally on:
   1. the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose; and
   2. legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
2. We have put in place appropriate technical and organisational security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We will ensure that the personal information that we hold is subject to appropriate security measures. We have in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally obliged to do so.

1. Your choices and rights

1. You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below. Please note that these rights will not apply in all cases or to all information that we hold about you. For example, we may need to continue to hold and process information to establish, exercise or defend our legal rights.
2. These rights include:
   1. Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information or where we need to request specific information from you to help us to confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client. You will not have to pay a fee to access your personal information (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
   2. Requesting that we correct your personal information if it is inaccurate or incomplete.
   3. Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
   4. Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
   5. Lodging a complaint with the information commissioner, if you think that any of your rights have been infringed by us. The information commissioner can be contacted at 0303 123 1113 or by completing the form at https://ico.org.uk/global/contact-us/email/. We would however appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.

1. Cookies

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1. How to contact us and other important information

If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at info@rkllp.com or Senior Partner, Rosling King LLP, 55 Ludgate Hill, London EC4M 7JW

Last updated: November 2022