UpDated Privacy Policy (as for requirements of GDPR)

05.04.2019

Definitions

«We» – We are L&T GLOBAL LP and We are a company incorporated in the Scotland with registration number SL019351 and registered office at Suite 7082, 4 Fullarton Street, Ayr, KA7 1UB, Scotland. Website that can be found in Internet via this link: https://lawstrust.com/lawstrust.com (also referred as to «We», «Company», «L&T»).

«You» - refers to You when You are visiting Our Websites, utilising Our services, products or communicating electronically with us.

«GDPR» means the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time and as transposed into member-state legislation.

«Privacy Policy» means this Privacy Policy updated from time to time and made public on Our Websites and through Our mobile applications.

«Personal Data» means any information which relates to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1. YOUR DATA PROTECTION RIGHTS

Under the GDPR you, as a data subject, have certain rights over the personal data that We hold and process.

At L&T GLOBAL LP, We are committed to make it easy for You to exercise these rights in the most transparent manner possible. You can exercise any of Your rights in relation to the data that L&T GLOBAL LP holds about you, by contacting Our data protection officer through the email address provided at the end of this section or through Your personal user cabinet on Your mobile device via the personal data management and protection applications We support.

The following are the specific rights You have over Your personal data We hold and process, namely:

 

1)The right to be informed about Our collection and processing of Your personal data including without limitation the legal basis for the collection and processing, the categories of data, the methods of data use, the envisaged period for which the personal data will be retained. This Privacy Policy should tell You everything You need to know, but You can always contact Us to find out more or to ask any questions.

 

2)The right to access Your personal data We collect about you, commonly referred to as “Subject Access Requests”, which provides you, as the data subject, the right to obtain a copy of Your personal data that We are processing for You

Pursuant to GDPR We are required to respond without undue delay to all Subject Access Requests in practice this means We have to respond within 1 month of receipt of the Subject Access Request.

Ordinarily Subject Access Requests are free of charge.

We may extend the time period for responding to a Subject Access Request by a further two months and may charge a reasonable fee if We deem the request to be manifestly unfounded or  excessive, however, We are required to advise You of Our intention to do this within 1 month of Your subject access request.

Should You wish to make a Subject Access Request this can be done by contacting the Company using the contact details in Section 9.

 

3)The right to have Your personal data rectified if any of Your personal data that We collect and process is in any way inaccurate or incomplete.

 

4)The right of erasure (otherwise known as “the right to be forgotten”), i.e. the right to ask Us to delete or otherwise dispose of any of Your personal data that We process. Please note that this is not an absolute right and We may not be able to comply with Your request as We may be legally obliged to continue to retain Your personal data for a specific period

 

5)The right to restrict (i.e. prevent) the processing of Your personal data by us.

 

6)The right to object to Us processing Your personal data for a particular purpose or purposes. Please note that the right to object only applies in certain circumstances and will depend on the purposes or legal basis for the processing.

 

7)The right to data portability. This only applies where You have provided personal data to Us directly, the legal basis for Us processing Your personal data is i) consent or ii) for the performance of a contract and We are processing Your data using automated means. In such instances  You have the right to receive Your personal data (or request that We transfer it to another Controller) in a structured, commonly used and machine readable format.

 

8)Rights relating to automated decision-making and profiling. We do not use Your personal data in this way.

 

9)The right to lodge a complaint with any relevant Data Protection Authority, in particular in the member State of Your residence, place of work or the place of processing Your personal data.

 

If You wish to exercise any of the aforementioned rights, please contact Us. We request that in the first instance You contact Our data protection officer at any time Our on info@lawstrast.com.

 

1. Introduction

We strongly respect Your privacy. This Privacy Policy details important information regarding the use and disclosure of user information collected on the Website https://lawstrust.com. Company provides this Privacy Policy to help You make an informed decision about whether to use or continue using of the Website.

Company reserves the right to amend the privacy policy at any time. In case of such amendment, Company shall publish a relevant notification of such changes on the official Web-Site.

Company shall gather Personal information (also referred as to PI, Personal Data, PD) only in scope, that is required for providing You with relevant services and that confirms with purposes of such collection.

Company shall gather Personal information only for purposes, that are stipulated in this Privacy Policy, or requirements, that follow from applicable law.

Our main purposes in gathering of information are to provide You with possibility to use and improve our Website, our services, and Website’s content to allow You use Website in an appropriate way.

We don’t store PI for a longer period of time, than it is required for maintaining of our services for You and other users.

 

2. PERSONAL DATA WE COLLECT ABOUT YOU

For using of certain Website functions, we have to collect from You several types of the Personal Information, including:

name, surname, contact phone number, email (during filling of the “feedback form”) – for purposes of further communication with You;

name, place of residence, contact phone number, email, login in “Skype” (during filling the “apply for a vacancy form”, but, such form is only displayed on Russian version of Website);

information about previously sent messages in “feedback form” for further communication with You;

after you submit the completed form, we determine the unique IP address of the host from which the message was sent.

We will not give, sell or rent Your email address, or any other personal information to third parties at any time for any reason without Your prior consent or request for it. Company reserves the right to transfer Your personal data to third parties only under official request of competent state bodies, Law enforcement, government officials, or other third parties when Company is compelled to do so by a subpoena, court order, or similar legal procedure; or under other obligatory provisions, that are stipulated in applicable law.

2.1. L&T GLOBAL LP will process Your personal data based on other legal bases such as:-

i) the performance of Our contract with You (i.e. the provision of Our Services to You);

ii) our legitimate business interests (i.e. for fraud prevention, maintaining the security of Our network and services, seeking to improve the Services that We provide and Your interaction with us). Whenever We rely upon on this lawful basis We assess Our business interests to make sure that they do not override Your rights. Furthermore, in some cases You have the right to object to this processing;

iii) with Your consent .for direct marketing purposes so that We may keep You fully up to date with other products and services that We supply and think may be of interest to you. Where We rely upon consent, We will need Your explicit consent, which may be removed at any time.

iv) with a legal obligation

2.2. CATEGORIES OF THE PERSONAL DATA WE COLLECT

Personal Data

When We collect

How We use

Why We use

email

When you filling our forms

Use email to communicate with you.

Necessary for the performance of a contract with you

We use Your e-mail address to inform You about the latest updates of Our Services and other products You may like. If You have subscribed to Our newsletter, We may send You marketing communications and information that will create an excellent customer experience

Only with Your explicit consent

phone number

When you filling our forms

We use this information to communicate with you

Necessary for the performance of a contract with you

name,
surname

When you filling our forms

We use this information to communicate with you

Necessary for the performance of a contract with you

Your message

When you contact us

We use this information to communicate with you

Necessary for the performance of a contract with you

unique identifiers, browser type and settings, device type and settings, operating system, mobile network information. We also collect information about the interaction of Your browsers and devices with Our services, including OS, IP address, URL of Your request

When You use Our services

We use it to optimise Our service and to improve Our app, Website, services, direct marketing, behaviour profiling and experiences

Necessary for Our legitimate interests

 

2.3. Purposes of Personal Information collection

We use Your Personal Information only:

  • for purposes of further communication with You;
  • for identification of You as our customer;
  • for identification of Your inquires;
  •  to administer Yours inquiries and requests;

We do not use “cookies”.

Other information, that is not deemed to be PI, can be used by us on our sole discretion.

 

3. PROTECTING YOUR PERSONAL DATA

We use, store and process Your personal data on L&T GLOBAL LP servers which are located on the France.

By filling a “consent application“ You agree to this conditions of collection, processing, transfer and storing Your personal data. When We process Your personal data for one of the legal bases specified in this Privacy Policy, We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy.

L&T GLOBAL LP protect Your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards L&T GLOBAL LP use are firewalls and data encryption, physical access controls to Our data centers, and information access authorization controls. L&T GLOBAL LP also authorize access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities. The L&T GLOBAL LP’s staff is trained on procedures for the management of personal information, including limitations on the release of information. Access to personal information is limited to those members of Our staff and contractors whose work requires such access. L&T GLOBAL LP conducts periodic reviews to ensure that proper information management policies and procedures are understood and followed. All of Our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations.

3.1.         HOW WE PROTECT YOUR DATA

When You provide Your personal data through Our Website, KYC portals, Our applications, this information is transmitted across the internet securely using industry standard encryption. Your personal data will be held encrypted on secure servers.

Where any third parties process Your personal data on Our behalf, We require that they have appropriate technical and organizational measures in place to protect this personal data and We will also ensure that a GDPR compliant. Data Processing Agreement is in place between L&T GLOBAL LP and the third party so that both parties understand their responsibilities and liabilities pursuant to GDPR.

 

4. Collection of Children’s PI

Children can only use our services under the supervision of their parents/legal guardians and we always suggest minors (under the age of 16) not to submit any personal information to us or use the service. Consent for processing of minor’ PI shall be given by their holder of parental responsibility over the minor.

Personal Company does not knowingly collect or maintain personally identifiable information or non-personally-identifiable information on the Company website from persons under 13 years of age, and no part of our website is directed to persons under 13. If You are under 13 years of age, then please do not use or access the Company website at any time or in any manner. If Company learns that personally identifiable information of persons less than 13 years of age has been collected on the Company website without verified parental consent, then Company will take the appropriate steps to delete this information.

5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We do not share Your Personal Data to third Parties, except cases that are mentioned in this Privacy Policy.

5.1.         With Your consent

We will share information with companies, organizations or individuals outside of L&T GLOBAL LP when We have Your explicit consent.

 

5.2.         TO COMPLY WITH THE LAW

We may share information in response to a request for information if We believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, We will attempt to provide You with prior notice before disclosing Your information in response to such a request.

 

5.3.         IN AN EMERGENCY

We may share information if We believe that it's necessary to protect the vital interests of the data subject (i.e. to prevent imminent serious physical harm or death to a person.)

 

5.4.         TO ENFORCE OUR POLICIES AND RIGHTS

We may share information if We believe Your actions are inconsistent with Our user agreements, rules, or other L&T GLOBAL LP policies, or to protect the rights, property, and safety of ourselves and others.

 

5.5.         WITH OUR AFFILIATES

We may share information between and among L&T GLOBAL LP and any of Our parents, affiliates, subsidiaries, and other companies under common control and ownership.

 

5.6.         WITH OUR PARTNERS

We may share information with vendors, consultants, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out processing activities for us. The partner’s use of personal data will be subject to appropriate confidentiality and security measures.

Where any third parties process Your personal data on Our behalf, We require that they have appropriate technical and organizational measures in place to protect this personal data and We will also ensure that a GDPR compliant .Data Processing Agreement  is in place between L&T GLOBAL LP and the third party so that both parties understand their responsibilities and liabilities pursuant to GDPR.

 

5.7          INTERNATIONAL TRANSFERS OF PERSONAL DATA

GDPR applies to controllers and processors located in the European Economic Area (“the EEA) and countries that the EU has deemed to provide adequate protection to data subjects from a data protection perspective.

 

Data Subjects risk losing the protection of GDPR if personal data is transferred outside of i) the EEA or ii) countries holding adequacy status and accordingly GDPR restricts such transfers, unless the rights of data subjects in respect of their personal data is protected by appropriate safeguards  or one of a limited number of exceptions applies (such exceptions include Your explicit and informed consent).

 

L&T GLOBAL LP will not make any international transfers of Your personal data to countries outside the EEA (or a country holding adequacy status) unless it has i) Your explicit and informed consent or ii) it has put in place the appropriate safeguards or iii) the international transfer is covered by an exception.

 

5.8          ADVERTISING, ANALYTICS AND BUSINESS PARTNERS (LIMITED TO NON-PERSONALLY IDENTIFIABLE INFORMATION)

We may share aggregated or pseudonymous information (including demographic information) with partners, such as publishers, advertisers, measurement analytics, apps, or other companies.  For example, We may tell an advertiser how its ads performed or report how many people installed an app after seeing a promotion.  We do not share information that personally identifies You (personally identifiable information is information like name or email address) with these partners, such as publishers, advertisers, measurement analytics, apps, or other companies.

 

5.9          OTHER INFORMATION

Other information, that does not personally identify You as an individual is collected by L&T GLOBAL LP (such as, by way of example, patterns of use) and is exclusively owned by L&T GLOBAL LP. We can use this information in such manner that L&T GLOBAL LP, in its sole discretion, deems appropriate.

We may share specific aggregated, non-personal information with third parties, such as the number of users who have registered with us, the volume and pattern of traffic to and within the site, etc. That information will not identify you, the individual, in any way.

We shall not use Your email or other contact information for sending of commercial proposal, other marketing needs, without Your prior consent.

In the light of the above, when You send Us messages, We can keep them for administering of Your inquiries, for improving of Our services. We shall not transfer information from such messages to third parties.

6. THIRD PARTY LINKS

You may find links to third party Websites on Our Website or chats of users contained on Our Website or mobile applications. These Websites should have their own privacy policies which You should check. We do not accept any responsibility or liability for their policies whatsoever as We have no control over them.

7. NOTIFICATION

In the case of a Personal Data breach, Company shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal information breach to the supervisory compent authority, unless the personal information breach is unlikely to result in a risk to the rights and freedoms of natural persons.

If Company learns of a security systems breach, then we may attempt to notify You electronically so that You can take appropriate protective steps. Company may post a notice on the Company website if a security breach occurs.

When the personal data breach is likely to result in a high risk to the rights and freedoms of users, the Companywill inform You.

In the event that Company is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our Users as part of such merger, acquisition, sale, or other change of control. If we become involved in a merger, acquisition, or any form of sale of some or all of its assets, we will notify Users before personal information is transferred and becomes subject to a different privacy policy. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how Your personal information is treated, transferred, or used.

8. Amendments to the Privacy Policy

Please note that this privacy policy may change from time to time. We will not reduce Your rights under this policy without Your explicit consent, and we expect most such changes will be minor. Regardless, we will post any policy changes on this page and, if the changes are significant, we will provide a more prominent notice. To continue usage of the Company’s services, You will be asked to fill consent application.

9. Contact us

If You have any questions about this policy, please feel free to contact us or to write to us at:

E-mail: info@lawstrast.com   

Correspondence address: 123112. Russian Federation. Moscow, Moscow-city, Presnenskaya 12, floor 41, office 2