Privacy Statement

Privacy statement

1. WHO WE ARE

When we talk about “HOS Partners LLP” (“HOS”) or “we”, “our” or “us” in this statement, we are talking about HOS. HOS fully respects your right to privacy and we are committed to ensuring that your privacy is protected. Please read the following to learn more about how we collect, use, process, and disclose your information, including personal information and how we keep it secure. For the purpose of the EU General Data Protection Regulation 2016/679 and the Data Protection Act 2018 (the “Act”), the data controller is HOS whose registered office is at 46 Fitzwilliam Square West, Dublin 2.

2. WHAT DOES THIS PRIVACY STATEMENT COVER

This Privacy Statement covers our treatment of your personal information that we gather when you are using our services or when you contact us in any manner. We gather various types of information, including information that identifies you as an individual (“Personal Information”) as explained in more detail below.

3. WHAT INFORMATION DO WE COLLECT

We collect information from you from three (3) main sources. This includes information we collect, (1) directly from you as a client, (2) for marketing and relationship management purposes, and (3) information we automatically collect when you visit our website.

3.1. Personal Information we collect directly from you as a client

We collect the following Personal Information directly from you or the organisation you are connected with when you or the organisation enquires about or engages us to provide legal advice or legal services:

Your name
Your employer, your job title and/or position
Documentation confirming your identity, such as your driving licence or passport
Your contact details include your postal address, email address and phone numbers
Your status as a director of a company
Your status as a beneficial owner of a company
Publicly available information
Your communications with staff of HOS
Your meetings with HOS
Financial information to make or receive payments to and from you
Any information which is provided to us by you or on your behalf

It is your responsibility to ensure that all Personal Information you provide us with is complete, accurate and up-to-date in all respects and not misleading. Our ability to provide our advice and services, and the quality thereof, may be negatively affected if you fail to do so.

You may provide Personal Information about yourself or about other people to us during the course of our dealings with you. Whenever you provide us with Personal Information about another person, you must ensure that you are entitled to disclose the Personal Information relating to that other person to HOS and that we may process that Personal Information in accordance with this Privacy Statement without having to take any further steps. It is your responsibility to ensure that the person concerned is aware of the content of this Privacy Statement.

3.2 Personal Information we collect for marketing and relationship management purposes

We may collect your Personal Data for marketing and relationship management purposes when you or your organisation contact us or communicate with any HOS staff, when you supply your Personal Information to us via email, by telephone or otherwise; when you subscribe to, or express interest in, any of our newsletters or mailing lists; and when you attend, or express an interest in, any of our events or seminars.

We collect the following Personal Information from you:

your name
your employer, your job title and/or position
your contact details, including your postal address, email address and phone number
your areas of interest

3.3 Personal Information we automatically collect when you visit our website

We may collect information when you visit our website. Please see our Cookie Policy below.

We collect the following Personal Information from you

the name of the domain and host from which you access the internet
the internet protocol (IP) address of the computer which you are using
the browser software you are using
the operating system you are using
the date and time at which you are accessing the Website

HOS will also collect information about your interaction with our Website using cookies. For more information on how we use cookies, please see our Cookie Policy below.

4.HOW DO WE USE AND PROCESS THE INFORMATION

4.1 Process and use of Personal Information we collect directly from you as a client

We use and process Personal Information that we collect as follows:

4.1.1 Purposes related to and ancillary to entering into and performing our contract with you

It is necessary to provide us with your Personal Information on this basis as it is necessary to provide our services to you. The consequence for not doing so is that we will not be able to perform the legal services for which you or your organisation engage us.

4.1.2 Where it is in our legitimate interest to do so. In particular

to enter into a contractual relationship with the organisation with which you are connected
to provide legal advice or other services or matters that the organisation has requested (including online internet or legal technology services or solutions for which our client engages us)
managing and administering the organisation’s business relationship with HOS, including processing payments, billing and collection and support services
to conduct client due diligence checks
for purposes related and/or ancillary to any of the above or any other purpose for which your Personal Information was provided to us.

When we process your Personal Information based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).

You have certain rights when we process your Personal Data on this basis. For more on exercising your data subject rights please see ‘Exercise my Data Subject Rights’.

4.1.3 To comply with legal obligations to which we are subject. In particular:

to comply with our legal and regulatory obligations (e.g. record keeping obligations)
to conduct client due diligence checks
to comply with our obligations under anti-money laundering and terrorist financing legislation
to comply as appropriate with the Law Society of Ireland, Chartered Accountants Ireland and other relevant governmental and/or regulatory authorities or bodies
to conduct conflict checks
to establish, exercise and defend our legal rights and any legal proceedings which may arise
to prevent, detect and respond to actual or potential fraud or other illegal activities

4.2 Personal Information we collect for marketing and relationship management purposes;

The Personal Information that we collect is processed and used as follows:

4.2.1 Where it is in our legitimate interest to do so. We have legitimate interests in:

promoting our firm
inviting you to events and meetings
developing and maintaining relationships with business contacts
conducting administrative and operational processes within our business
protecting the security and integrity of our premises, IT systems, online platforms and other systems
managing and administering our relationship with our business contacts and with our clients
sending you marketing material, newsletters, legal updates and other information

You have certain rights when we process your Personal Data on this basis. For more on exercising your data subject rights please see ‘Exercise my Data Subject Rights’.

4.3 Personal Information we automatically collect when you visit our website.

The Personal Information that we collect is processed and used as follows:

4.3.1 Where it is in our legitimate interest to do so. We have legitimate interests in:

providing you with access to our Website and enabling you to use it
conducting administrative and operational processes within our business
protecting the security and integrity of our online platforms, IT systems and other systems
providing, improving, monitoring and testing the effectiveness of our Website
ensuring the content on the Website is presented in an effective, accessible and user-friendly format
monitoring metrics such as numbers of visitors, traffic data and demographic patterns

You have certain rights when we process your Personal Data on this basis. For more on exercising your data subject rights please see ‘Exercise my Data Subject Rights’.

5. HOW DO WE SHARE YOUR PERSONAL INFORMATION

5.1 Personal Information we collect directly from you as a client

We may disclose some or all of the Personal Information we collect from you to certain trusted third parties in accordance with contractual arrangements we have in place with these third parties or as required by law, including:

third parties such as barristers, foreign counsel, consultants, expert witnesses, advisors and technology service providers such as data room providers
other people in your organisation
our auditors and professional advisors
suppliers and service providers to whom we outsource support services
IT service providers
parties involved in hosting or organising events or seminars
regulators and official authorities

5.2 Personal Information we collect for marketing and relationship management purposes

third parties who assist us in marketing and promoting the firm
suppliers and service providers to whom we outsource support services
IT service providers
third parties involved in hosting or organising events or seminars

5.3 Personal Information we automatically collect when you visit our website.

suppliers and service providers to whom we outsource support services
IT service providers

6. IS PERSONAL INFORMATION ABOUT ME SECURE

We use appropriate technical, organisational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction.

While HOS takes all due care in ensuring the privacy and integrity of the information that you provide to us, we recognise that no data transmission over the internet can be 100% guaranteed as secure. The possibility exists that this information could be unlawfully observed by a third party while in transit over the internet. HOS accepts no liability should this occur.

7. HOW LONG WILL WE USE YOUR PERSONAL INFORMATION FOR

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. COOKIES POLICY

Cookies – A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. For more information on how to manage or disable cookies, please visit www.aboutcookies.org and www.allaboutcookies.org.

We use cookies to:

Remember that you have visited us before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get
Customise elements of the promotional layout and/or content of the pages of the Site
Collect statistical information about how you use the website (including how long you spend on the site) and where you have come to the site from, so that we can improve the site and learn which parts of the site are most popular with visitors
To speed site navigation and recognise your access rights on the site

Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting https://en.wikipedia.org/wiki/HTTP_cookie which includes additional useful information on cookies and how to block cookies using different types of browser. Please note, however, that by blocking or deleting cookies used on the website, you may not be able to take full advantage of the site.

The cookies used by us fall into these main categories:

Necessary
Functionality
Performance
Analytics

We also may use clear gifs in HTML-based emails sent to our users to track which emails are opened by recipients. This information is used to enable more accurate reporting, improve the effectiveness of our marketing, and make our Services and Websites better for our users. We also utilise Google Analytics, a web analysis service provided by Google, to better understand your use of our Websites and Services. Google Analytics collects information such as how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google offers an opt-out mechanism for the web available here.

9. MARKETING COMMUNICATIONS

If you have consented to receiving certain promotional or marketing communications from us, you can opt-out of receiving such promotional or marketing communications from us at any time, by using the unsubscribe link in the emails communications we send, or send us an email to info@hos.ie

10. EXERCISE MY DATA SUBJECT RIGHTS

You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:

• Right to access the data – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data

• Right to rectification– you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.

• Right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.

• Right to restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.

•. Right to data portability – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine-readable format.

In order to exercise any of the rights set out above, please contact us at the contact details at the start of this privacy notice.

If we are processing personal data based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal.

If you are unhappy with how we process personal information, we ask you to contact us so that we can rectify the situation.

You may lodge a complaint with a supervisory authority. The Irish supervisory authority is the Data Protection Commission.

11. WILL HOS EVER CHANGE THIS PRIVACY STATEMENT

We may need to change this Privacy Statement from time to time. We will alert you to material changes by, for example, placing a notice on our website and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law. You are responsible for periodically reviewing this Privacy Statement.

This Privacy Statement was most recently updated on 23/05/2018.

12. WHAT IF I HAVE QUESTIONS ABOUT THIS PRIVACY STATEMENT

If you have any questions or concerns regarding this Privacy Statement/or the HOS privacy policies, please send us a detailed message to info@hos.ie and we will try to resolve your concerns.

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